Case Summary (G.R. No. 197539)
Procedural Background
This legal matter is presented as consolidated petitions for review on certiorari that challenge the March 21, 2013 Decision and the September 12, 2013 Resolution of the Court of Appeals, which upheld the November 5, 2008 Decision of the Regional Trial Court (RTC) of Quezon City, Branch 225. The RTC declared Reghis and Olivia's marriage null and void ab initio based on psychological incapacity as defined under Article 36 of the Family Code of the Philippines.
The Facts of the Case
Reghis and Olivia's marriage was characterized by significant turbulence, often resulting in violent confrontations. Reghis later filed for annulment, citing psychological incapacity, asserting that he entered marriage not out of love but to satisfy Olivia's parents. He presented the testimony of Dr. Valentina Nicdao-Basilio, a psychologist, who diagnosed him with Obsessive Compulsive Personality Disorder (OCPD), claiming it prevented him from fulfilling his marital obligations. Meanwhile, Olivia claimed that they were capable of fulfilling their marital responsibilities and contended that Reghis had previously sought similar annulment claims against her.
RTC's Findings
The RTC ruled in favor of Reghis, citing the testimony from Dr. Basilio to support the claim of psychological incapacity, which it considered serious and incurable. It held that Reghis was unable to meet the essential marital obligations of love and responsibility, concluding that his condition rendered the marriage null and void from its inception. The RTC also found no merit in Olivia's argument of res judicata, stating that the current case was distinct from previous claims.
Court of Appeals' Ruling
The Court of Appeals affirmed the RTC's ruling, agreeing that Reghis's OCPD qualified as a psychological incapacity under Article 36 of the Family Code. The appellate court found his condition to be serious and deeply rooted, impacting his marriage and further found that it predated his marriage, thus asserting that the incapacity was both grave and incurable.
Proceedings Before the Supreme Court
Both the Republic of the Philippines and Olivia appealed the Court of Appeals' decision. The Republic maintained that Reghis had not sufficiently proved the severity or gravity of his psychological condition nor its juridical antecedence. Olivia echoed similar sentiments, highlighting that she believed Reghis was aware of his obligations during their marriage and could have opted out if he did not wish to commit.
Legal Issues Presented
The main legal issue addressed by the Supreme Court is whether the Court of Appeals erred in upholding the RTC's declaration of nullity based on alleged psychological incapacity.
Supreme Court's Analysis and Ruling
The Supreme Court ultimately found merit in the petitions. It emphasized the constitutional policy that upholds the indissolubility of marriage, asserting that psychological incapacity must arise from serious, permanent disorders that significantly impair one’s ability to
...continue readingCase Syllabus (G.R. No. 197539)
Case Background
- The case involves consolidated petitions for review on certiorari pertaining to the marriage of Reghis M. Romero II and Olivia Lagman Romero.
- The petitions challenge the March 21, 2013 decision and September 12, 2013 resolution of the Court of Appeals, which upheld the Regional Trial Court's (RTC) earlier decision declaring the couple's marriage null and void ab initio on the ground of psychological incapacity, as defined in Article 36 of the Family Code of the Philippines.
- The marriage took place on May 11, 1972, and the couple had two children.
Factual Background
- Reghis and Olivia met in 1971, leading to a relationship influenced by familial pressures, particularly from Olivia's parents, which contributed to their marriage.
- The couple's marriage was marked by conflict, jealousy, and estrangement, culminating in their separation in 1986.
- In 1998, Reghis filed for declaration of nullity of marriage, claiming psychological incapacity, supported by testimony from a clinical psychologist, Dr. Valentina Nicdao-Basilio, who diagnosed him with Obsessive Compulsive Personality Disorder (OCPD).
Psychological Evaluation and Testimony
- Dr. Basilio’s evaluation concluded that Reghis’ OCPD significantly affected his ability to fulfill marital obligations, attributing the couple's conflicts to his condition.
- Reghis claimed he married Olivia not out of love, but to please her parents, highlighting his lack of readiness for marria