Case Summary (G.R. No. 237524)
Factual Background
Petitioner and respondent met and courted while working in Taiwan in October 1996, learned that petitioner was pregnant, returned to the Philippines, and were married on June 19, 1997 before Judge Ofelia Arellano Marquez of the Metropolitan Trial Court of Quezon City. The couple had two children and at first experienced a peaceful union, but marital relations deteriorated amid recurrent quarrels about respondent’s unemployment, respondent’s drinking, gambling, and womanizing, and respondent’s repeated references to petitioner’s traumatic past. Respondent worked abroad as an entertainer in Japan from February 2000, listed his civil status as “single” in his passport according to petitioner, intermittently remitted money, and in June 2002 ceased sending support and contact. After a prolonged absence, respondent informed petitioner through a family member that he would not return and that he was living with another woman.
Trial Court Proceedings
Petitioner filed a petition for declaration of nullity of marriage on the ground of psychological incapacity under Article 36 of the Family Code. Respondent did not file a responsive pleading. The Office of the Solicitor General entered its appearance, and the RTC conducted an inquiry for collusion and found none. Petitioner submitted, among other exhibits, a psychological report by clinical psychologist Dr. H. Nedy L. Tayag, based primarily on petitioner’s account, interviews with the parties’ two children, and an interview with respondent’s younger brother who was available at respondent’s residence. The report concluded that respondent suffered from antisocial personality disorder that rendered him incapable of performing marital duties.
Ruling of the Regional Trial Court
In its December 28, 2011 Decision, the RTC granted the petition and declared the marriage null and void ab initio, relying on the findings of the psychological report and concluding that petitioner proved by the evidence that respondent was psychologically incapacitated to perform essential marital obligations at the time of the celebration of the marriage. The Solicitor General filed a motion for reconsideration, which the RTC denied in an order dated March 23, 2012.
Ruling of the Court of Appeals
The Court of Appeals, in its June 16, 2017 Decision, reversed the RTC and held that the totality of the evidence was insufficient to establish that respondent was psychologically incapacitated under Article 36 of the Family Code. The CA found that Dr. Tayag’s report failed to fully explain the symptoms of the alleged antisocial personality disorder and to establish a causal link between respondent’s acts and an antecedent, grave, and incurable psychological incapacity. Petitioner’s motion for reconsideration before the CA was denied in the Resolution dated November 16, 2017.
Issue Presented to the Supreme Court
Whether the Court of Appeals erred in reversing the RTC’s declaration of nullity and in finding that petitioner failed to prove by clear and convincing evidence that respondent was psychologically incapacitated to perform his essential marital obligations as required by Article 36 of the Family Code.
Supreme Court’s Disposition
The Supreme Court denied the petition for review and affirmed the June 16, 2017 Decision and the November 16, 2017 Resolution of the Court of Appeals, thereby dismissing the petition for declaration of nullity of marriage filed under Article 36 of the Family Code.
Legal Basis and Reasoning
The Court reiterated that the burden of proof to establish nullity on the ground of psychological incapacity rests upon the plaintiff-spouse and must be borne by clear and convincing evidence. The Court relied on its prior exposition in Santos v. Court of Appeals, Republic v. Court of Appeals and Molina, and the subsequent refinement of the Molina guidelines in Tan-Andal v. Andal, which clarified the characteristics of psychological incapacity as comprising gravity, juridical antecedence, and incurability in the legal sense. The Court emphasized that the presumption of the validity of marriage, rooted in the Constitution and the laws that cherish the family, requires that any doubt be resolved in favor of the continuation of the marriage.
Application of Doctrine to the Evidence
Applying the modified Molina guidelines, the Court found that although respondent plainly failed to fulfill essential obligations through abandonment and lack of support, the evidentiary record did not show that such conduct was the product of a genuinely serious and antecedent psychic cause. The Court examined Dr. Tayag’s report and determined that it relied heavily on petitioner’s account and contained conjectural inferences about respondent’s upbringing and personality structure that were not corroborated by other sources. The partie
...continue reading
Case Syllabus (G.R. No. 237524)
Parties and Posture
- Bebery O. Santos-Macabata filed a petition for declaration of nullity of marriage under Article 36 of the Family Code against Flaviano Macabata, Jr. and the Republic of the Philippines before the RTC.
- The Regional Trial Court, Branch 90, Dasmariñas City, Cavite granted the petition and declared the marriage null and void ab initio.
- The Office of the Solicitor General entered its appearance and moved for reconsideration before the RTC, which the RTC denied.
- The Court of Appeals reversed the RTC Decision and denied the petitioner's motion for reconsideration.
- The petitioner elevated the case to the Supreme Court by a petition for review on certiorari under Rule 45.
Key Facts
- Petitioner and respondent met and courted while working as factory workers in Taiwan in October 1996, and the parties married on June 19, 1997.
- The parties had two children and initially lived in Caloocan City before moving to the petitioner’s parents' home due to financial difficulty.
- The respondent went to work as an entertainer in Japan in February 2000 and allegedly represented his civil status as “single” in his passport.
- The respondent ceased sending sufficient financial support beginning June 2002 and ceased communication for approximately two years before informing the petitioner that he would not return because he was living with another woman.
- The petitioner filed the petition for nullity on August 13, 2010, alleging that the respondent suffered from psychological incapacity to comply with essential marital obligations.
- The petitioner submitted a psychological report by clinical psychologist Dr. H. Nedy L. Tayag concluding that the respondent suffered from antisocial personality disorder; the report relied largely on information from the petitioner, the parties’ children, and a visit in which the psychologist interviewed the respondent’s younger brother.
- The report contained conjectural findings about the respondent’s upbringing and concluded that the respondent’s alleged pathological personality disposition rendered him incapacitated to execute spousal roles.
Procedural History
- The RTC rendered its Decision granting the petition on December 28, 2011.
- The OSG filed a motion for reconsideration before the RTC which the trial court denied in an Order dated March 23, 2012.
- The Court of Appeals reversed the RTC Decision in a Decision dated June 16, 2017 and denied the petitioner’s motion for reconsideration in a Resolution dated November 16, 2017.
- The Supreme Court denied the petition for review on certiorari and affirmed the Court of Appeals decision.
Issue
- The controlling issue was whether the Court of Appeals erred in reversing the RTC by finding that the petitioner failed to prove by clear and convincing evidence that the respondent was psychologically incapacitated to perform essential marital obligations under Article 36 of the Family Code.
Statutory Framework
- Article 36 of the Family Code provides that a marriage is void when a party was psychologically incapacitated at the time of the celebration to comply with essential marital obligations.
- Santos v. Court of Appeals was cited for the three hallmark characteristics of psychological incapacity: gravity, juridical antecedence, and incurability.
- Republic v. Court of Appeals and Molina supplied earlier guidelines fo