Case Summary (G.R. No. 171557)
Facts of the Case
Rodolfo and Natividad were married on February 15, 1969, in Salug, Zamboanga del Norte. They had two children together, Ma. Reynilda and Ma. Rizza. In December 1998, Rodolfo filed a verified complaint for the declaration of nullity of their marriage, alleging Natividad's psychological incapacity to fulfill her essential marital obligations. Following an investigation, the RTC found that there was no collusion between the spouses. Rodolfo testified that their marriage was forced due to Natividad's accidental pregnancy and highlighted multiple instances of her abandonment and lack of cooperation. Natividad did not respond to the complaint or attend the trial, but during the proceedings, a psychiatric evaluation was conducted for both parties.
Psychiatric Evaluation
The psychiatric evaluation conducted by Dr. Cheryl T. Zalsos reported that both Rodolfo and Natividad exhibited signs of psychological incapacity stemming from emotional immaturity. Dr. Zalsos concluded that their psychological conditions existed at the time of the marriage but only became evident later. Natividad specifically was noted to lack the willful cooperation necessary for her role as a wife and mother.
RTC Ruling
The Regional Trial Court ruled on October 17, 2000, that the marriage was void due to psychological incapacity, relying heavily on Dr. Zalsos's findings. The court noted that Natividad’s emotional immaturity and personality disorder affected her ability to understand and assume marital obligations.
CA Ruling
The Court of Appeals affirmed the RTC's ruling on June 2, 2005, finding that Natividad's emotional issues constituted a severe psychological disorder that incapacitated her from fulfilling her marital duties. The Republic, represented by the OSG, appealed this decision.
Issue Before the Court
The primary issue was whether the Court of Appeals erred in upholding the RTC's declaration of psychological incapacity.
Ruling of the Court
The Supreme Court found the petition meritorious, emphasizing that “psychological incapacity” under Article 36 of the Family Code denotes a serious mental inability. The law's intent is to confine psychological incapacity to severe personality disorders that render a party incapable of comprehending marital obligations. Citing Santos v. CA and other precedents, the Court outlined that psychological incapacity must be grave, rooted in history predating the marriage, and incurable.
Evaluation of Evidence
The Court scrutinized Dr. Zalsos's evaluations and reports, finding them insufficient to establish that Natividad’s behavior constituted psychological incapacity. The court noted that Dr. Zalsos's report lacked detail regarding the specific nature of Natividad's psychological condition, its root ca
...continue readingCase Syllabus (G.R. No. 171557)
Case Overview
- This case involves a petition for review on certiorari filed by the Republic of the Philippines against Rodolfo O. De Gracia.
- The case centers on the validity of the marriage between Rodolfo and Natividad N. Rosalem, which was declared void by the Regional Trial Court (RTC) based on psychological incapacity.
- The decision of the RTC was affirmed by the Court of Appeals (CA), leading to the current petition.
Background of the Case
- Rodolfo and Natividad were married on February 15, 1969, and lived in Zamboanga del Norte.
- They had two daughters, Ma. Reynilda and Ma. Rizza.
- Rodolfo filed a complaint for declaration of nullity of marriage on December 28, 1998, asserting that Natividad was psychologically incapacitated to fulfill her marital obligations.
- An investigation by the public prosecutor found no collusion between the parties.
Testimonies and Evidence Presented
- Rodolfo testified about their forced marriage due to Natividad's accidental pregnancy and described his unstable employment.
- Natividad later abandoned the family and entered into relationships with other men, including marrying Antonio Mondarez in 1991.
- Both parties underwent psychiatric evaluations by Dr. Cheryl T. Zalsos, who reported that the