Case Summary (G.R. No. 170022)
Factual Antecedents
Cesar married Lolita on August 25, 1979, and the couple had two children during their union. In pursuit of financial stability, Cesar worked in Saudi Arabia starting May 15, 1984. He discovered Lolita's alleged illicit affair with Alvin Perez on June 12, 1986. By 1991, Lolita had reportedly left the conjugal home to live with Alvin, resulting in their separation. On June 16, 1995, Cesar filed a petition with the Regional Trial Court (RTC) seeking to declare their marriage null based on Lolita's psychological incapacity. Though Lolita denied the affair and claimed she left due to irreconcilable differences with her mother-in-law, Cesar maintained that he provided financial support to her and their children even after the allegations surfaced.
The RTC Ruling
In its decision rendered on June 5, 2002, the RTC found sufficient grounds to declare the marriage void, determining that Lolita was psychologically incapacitated to fulfill her marital obligations. The Petitioner, represented by the Office of the Solicitor General (OSG), subsequently appealed to the Court of Appeals (CA).
The CA Ruling
Initially, the CA reversed the RTC’s ruling, concluding that Lolita’s actions of abandonment and infidelity did not amount to serious psychological disorders but merely indicated a refusal to meet her marital responsibilities. However, upon Cesar's motion for reconsideration, the CA ultimately affirmed the RTC’s decision in an amended ruling, considering Lolita's refusal to perform her duties and her abandonment as indicators of serious psychological incapacity.
The Petition
The OSG contended that Dr. Flores' psychological evaluation did not substantiate the claim of psychological illness and failed to establish its juridical antecedence, severity, and irreparability. They argued that infidelity and abandonment did not constitute psychological incapacity but were grounds for legal separation.
The Case for the Respondent
Cesar argued that Lolita’s actions constituted severe and incurable psychological incapacity, thereby providing sufficient grounds for nullifying their marriage.
The Issue
The central issue presented before the court was whether there existed valid grounds for annulling the marriage on psychological incapacity.
The Court's Ruling
The Supreme Court ruled in favor of the petitioner, concluding that there was no sufficient basis to annul Cesar's marriage to Lolita on the grounds of psychological incapacity.
Applicable Law and Jurisprudence on Psychological Incapacity
The ruling was guided by Article 36 of the Family Code, which states that a marriage is void if one party is psychologically incapacitated to comply with essential marital obligations at the time of celebration. The Court emphasized that psychological incapacity implies a profound incapacity to understand and fulfill basic marital duties and cannot be equated merely to refusal, neglect, or difficulty.
Failure to Prove Psychological Incapacity
The Court found that Cesar had failed to substa
...continue readingCase Syllabus (G.R. No. 170022)
Case Overview
- The case involves a petition for review on certiorari filed by the Republic of the Philippines against Cesar Encelan concerning the nullity of marriage based on psychological incapacity.
- The petition challenges the Court of Appeals' decision that reconsidered a prior ruling regarding the declaration of nullity of marriage.
Factual Antecedents
- Cesar Encelan married Lolita on August 25, 1979, and they had two children, Maricar and Manny.
- Cesar began working in Saudi Arabia on May 15, 1984, and learned of Lolita's alleged affair with Alvin Perez on June 12, 1986.
- By 1991, Lolita reportedly left their home with the children to live with Alvin, leading to a separation between Cesar and Lolita.
- On June 16, 1995, Cesar filed a petition for the declaration of nullity of his marriage, citing Lolita's psychological incapacity.
- Lolita denied infidelity, stating the affair was a misunderstanding related to her promotions business and claimed she left due to irreconcilable differences with her mother-in-law.
- Cesar continued to provide financial support even after discovering Lolita’s alleged infidelity.
Psychological Evaluation
- Cesar presented a psychological evaluation report by Dr. Fareda Fatima Flores, which concluded that Lolita did not exhibit any major psychiatric illness.
- The report indicated some interpersonal issues and a lack of fulfillment in marital obligations, but did not establish psychologi