Case Summary (G.R. No. 112019)
Key Dates
20 September 1986
Civil marriage solemnized in Iloilo City before MTC Judge Cornelio G. Lazaro; followed by a church wedding.
18 July 1987
Birth and christening of the couple’s son.
18 May 1988
Julia departed for the United States to work as a nurse.
1 January 1989
Julia’s first telephone contact with Leouel after seven months.
10 April–25 August 1990
Leouel’s training in the United States; unsuccessful efforts to locate Julia.
31 May 1991
Julia filed her answer, denying allegations and accusing Leouel of irresponsibility.
25 October 1991
Julia manifested she would neither appear nor present evidence.
6 November 1991
RTC of Negros Oriental, Branch 30, dismissed Leouel’s complaint for lack of merit.
Court of Appeals
Affirmed the trial court decision.
Applicable Law
1987 Philippine Constitution
Article XV, Sections 1–2: Marriage and the family as inviolable social institutions.
Family Code (E.O. No. 227, 17 July 1987)
Article 36: Marriage void ab initio if, at celebration, a party was psychologically incapacitated to comply with essential marital obligations, even if manifested only after solemnization.
Facts and Contentions
• Leouel and Julia lived with her parents; conflicts arose over parental interference and domestic arrangements.
• Julia’s abrupt departure to the U.S. and minimal communication thereafter.
• Leouel’s repeated but unreciprocated efforts to reestablish contact.
• Petition for annulment filed under Article 36, alleging Julia’s prolonged absence demonstrated psychological incapacity.
Deliberations of the Family Code Revision Committee
• Article 36 drawn from Canon 1095 of the New Code of Canon Law, shifted from “vice of consent” to incapacity affecting essential obligations.
• Committee debates clarified that psychological incapacity:
– Must exist at time of marriage and be grave, antecedent, and incurable.
– Differs from insanity or mental defect vitiating consent (grounds for voidable marriage).
– Requires case-by-case judicial assessment guided by expert evidence and persuasive Canon Law jurisprudence.
• Ten-year prescriptive period imposed for actions declaring nullity under Article 36.
Analysis and Interpretation
• Psychological incapacity entails a serious personality disorder so profound that one cannot appreciate or perform fundamental marital duties (living together, affection, fidelity, support, procreation).
• It must be proven that the incapacity was present at the time of marriage and remained incurable, with its manifestation possibly delayed.
• Mere abandonment or failure to communicate does not, without more, establish the deep-rooted psychologic defect
Case Syllabus (G.R. No. 112019)
Facts of the Case
- Leouel Santos, then First Lieutenant in the Philippine Army, met Julia Rosario Bedia in Iloilo City.
- They exchanged civil vows on 20 September 1986 before Municipal Trial Court Judge Cornelio G. Lazaro, followed by a church wedding.
- The couple lived with Julia’s parents in La Paz, Iloilo City, and on 18 July 1987 Julia gave birth to Leouel Santos, Jr.
- Marital tensions arose from frequent parental interference and disagreements over independent living and visits to each other’s families.
- On 18 May 1988 Julia left for the United States to work as a nurse despite Leouel’s pleas.
- Julia first telephoned Leouel on 1 January 1989, promising to return in July 1989, but she never did.
- During his training in the U.S. from 10 April to 25 August 1990, Leouel attempted to locate Julia without success.
Procedural History
- Leouel filed in the Regional Trial Court of Negros Oriental (Civil Case No. 9814) a complaint to void the marriage under Article 36 of the Family Code.
- Summons was effected by publication; Julia answered on 31 May 1991, denying allegations and accusing Leouel of irresponsibility.
- The provincial prosecutor found no collusion between the parties.
- Julia manifested on 25 October 1991 that she would neither appear nor present evidence.
- On 6 November 1991, the RTC dismissed the complaint for lack of merit.
- Leouel appealed to the Court of Appeals, which affirmed the RTC decision and dismissed the petition for non-compliance with Circular 28-91 and lack of merit.
- Leouel sought review by certiorari in the Supreme Court.
Legal Provision Invoked
- Article 36 of the Family Code (as amended by E.O. No. 227, 17 July 1987):
“A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage shall likewise be void even if such incapacity becomes manifest only after its solemnization.”
Petitioner’s Claim
- The prolonged absence