Case Summary (G.R. No. 188400)
Factual Background
Petitioner and respondent met as students, courted, and married in 1984. Early in the relationship petitioner observed respondent’s introversion, pronounced jealousy, lack of ambition and insecurity. During marriage respondent’s jealousy escalated into stalking, intimidation of those who spoke with petitioner, extreme sexual demands (including coerced frequent intercourse, tying, and poking with objects), proposals to involve third parties in sexual acts, and physical violence (notably placing a gun at petitioner’s head and at a teenage cousin). Petitioner made repeated efforts to seek help (doctors, lawyer, priest) and to propose counseling, which respondent refused. After a 1986 gun‑poking incident petitioner left the conjugal home with the children and supported them thereafter.
Procedural History
Petitioner filed a petition for declaration of nullity of marriage in June 1999. The case underwent initial procedural delays, a collusion inquiry by the city prosecutor (no collusion found), and pretrial proceedings in which respondent failed to file a responsive pleading or to appear. Petitioner presented evidence including the testimony and psychological evaluation of Dr. Arnulfo V. Lopez. The trial court credited Dr. Lopez and petitioner, found respondent psychologically incapacitated, and granted the petition in a decision of August 14, 2002 (dissolving the marriage, leaving legitimacy and custody of the children to petitioner, and leaving support unresolved). The Office of the Solicitor General filed motions and later appealed. The Court of Appeals reversed, finding the expert testimony unreliable and insufficient under Molina, and dismissed the petition. The Supreme Court then granted certiorari review.
Expert Evidence Presented at Trial
Dr. Arnulfo V. Lopez, clinical psychologist, conducted an in‑depth interview of petitioner, administered psychological tests to her, and interviewed respondent’s best friend (and referenced other informants). Dr. Lopez concluded petitioner did not suffer a severe mental disorder but diagnosed respondent with paranoid personality disorder. He described respondent’s condition as severe, hereditary (noting the father’s psychiatric history), likely beginning in late childhood/adolescence, resistant to treatment, and effectively incurable in practical terms. Dr. Lopez attributed respondent’s behavior (extreme jealousy, distrust, reckless behavior, emotional coldness, lack of remorse, resistance to treatment) to this disorder and recommended annulment based on incapacity to assume essential marital obligations. Respondent declined direct examination by Dr. Lopez and did not appear to present evidence.
Issues Raised on Appeal
The central issue addressed by the appellate courts and the Supreme Court was whether petitioner’s evidence sufficed to prove respondent’s psychological incapacity under Article 36. The Court of Appeals held Dr. Lopez’s testimony was unreliable and effectively hearsay because Dr. Lopez did not personally examine respondent and relied on petitioner’s accounts; it also found that petitioner’s prior belief respondent would change and their five‑year courtship suggested absence of juridical antecedence. The Office of the Solicitor General likewise argued that the report relied on unnamed informants and that expert evidence was deficient under Molina.
Legal Standards for Psychological Incapacity (Santos and Molina)
The Court reiterated controlling jurisprudence: Santos articulated that psychological incapacity must show gravity, juridical antecedence, and incurability. Molina supplied guidelines requiring: (1) plaintiff bears the burden of proof and doubts favor the marriage; (2) the root cause must be medically or clinically identified, alleged in the complaint, sufficiently proven by experts and clearly explained in the decision; (3) the incapacity must have existed at the time of the marriage; (4) the condition must be permanent or incurable (absolute or relatively, insofar as relevant to the spouse); (5) the illness must be grave enough to disable assumption of essential marital obligations; (6) non‑compliance must relate to essential marital obligations (Articles 68–71; pertinent parental provisions); (7) persuasive weight may be given to canonical interpretations; and (8) the Solicitor General must be ordered to appear and issue a certification before decision is rendered.
Supreme Court’s Analysis on Evidence Sufficiency
The Supreme Court found that the trial court had sufficient basis to conclude psychological incapacity existed. It emphasized that Molina does not rigidly require personal examination of the allegedly incapacitated spouse by the expert; Camacho‑Reyes and Marcos demonstrate that non‑examination does not automatically render expert findings hearsay where the totality of evidence, including the intimate spouse’s testimony and corroborating facts, establish the mental condition. The Court accepted Dr. Lopez’s diagnosis and the trial court’s factual findings as adequately rooted in observed behavior, credible informants, and corroboration by petitioner’s testimony regarding long‑standing jealousy, stalking, sexual coercion, and violent acts (including the gun incident). The Court concluded these behaviors manifested a root psychological cause (paranoid personality disorder), had juridical antecedence predating or attaching at the time of marriage, and were of such severity and practical incurability (given respondent’s resistance to treatment) as to incapacitate him from performing essential marital obligations (love, respect, support).
Consideration of Psychological Abuse and Statutory Context
The Supreme Court recognized the pattern of coercive co
...continue readingCase Syllabus (G.R. No. 188400)
Case Caption and Decision
- Reported as 807 Phil. 31, Second Division, G.R. No. 188400, decided March 8, 2017; opinion by Justice Leonen.
- Petitioner: Maria Teresa B. Tani-De La Fuente; Respondent: Rodolfo De La Fuente, Jr.
- This is a Petition for Review of the Court of Appeals Decision and Resolution dated August 29, 2008 and May 25, 2009 in CA-G.R. CV. No. 76243, which reversed the Regional Trial Court (RTC), Branch 107, Quezon City, Decision dated August 14, 2002 in Civil Case No. Q-99-37829 (trial court had granted petition for declaration of nullity of marriage) [Rollo references throughout].
Procedural Posture
- Original petition for declaration of nullity filed by Maria Teresa on June 3, 1999 before the RTC, Quezon City. Case initially archived for respondent's failure to file a responsive pleading [Rollo, p. 151; pp. 82-95].
- Petitioner moved to revive; trial court referred case to Office of the City Prosecutor for collusion investigation. Assistant City Prosecutor Jocelyn S. Reyes found no collusion and recommended trial on the merits [Rollo, pp. 153; 83].
- Respondent failed to appear at pre-trial, at trial, and did not file responsive pleadings; trial court declared pre-trial closed and permitted petitioner to present evidence; respondent’s non-appearance was deemed a waiver of his right to present evidence [Rollo, pp. 83-90].
- Trial court directed Office of the Solicitor General (OSG) to submit comment and certification; OSG failed to comply and the case was submitted without such certification and comment [Rollo, pp. 41; 49].
- RTC promulgated Decision dated August 14, 2002 granting annulment on ground of respondent’s psychological incapacity under Article 36 of the Family Code; judgment dissolved conjugal partnership, left children legitimate and in petitioner’s custody, and allowed petitioner to revert to maiden name Tani; noted absence of property pronouncements and lack of respondent support pronouncement for the time being [Rollo, pp. 82-95; dispositive portion quoted] (emphasis in original).
- OSG filed motion for reconsideration August 20, 2002, explaining inability to submit required certification due to lack of transcripts; trial court denied motion as moot and academic on September 13, 2002 [Rollo, pp. 42; 56].
- OSG appealed to the Court of Appeals arguing: (a) error in deciding without OSG certification; and (b) undue credence given to Dr. Arnulfo V. Lopez’s findings concerning respondent’s personality disorder, claiming insufficient data and noncompliance with Molina standards [Rollo, pp. 83; 50].
- Court of Appeals reversed RTC, dismissed petition for nullity, holding Dr. Lopez’s testimony unreliable as hearsay and finding petitioner’s admissions undermined the element of juridical antecedence and existence of incapacity at time of marriage; petitioner’s motion for reconsideration denied May 25, 2009 [Rollo, pp. 37-53; 55-56].
- Petitioner filed Petition for Review on Certiorari to the Supreme Court on July 24, 2009 [Rollo, pp. 12-35]; the Supreme Court granted the petition, reversed CA decision and reinstated RTC Decision (marriage declared null and void) [final disposition].
Facts of the Marriage and Marital Life
- Petitioner and respondent met as students at the University of Sto. Tomas, became sweethearts, and married on June 21, 1984 in Mandaluyong City [Rollo, pp. 83; 84; 10].
- Petitioner worked at the University of Sto. Tomas Treasurer’s Office after graduation; respondent continued employment at the family printing press and did not finish college [Rollo, pp. 84; 7].
- The couple had two daughters: Maria Katharyn (b. May 23, 1985) and Maria Kimberly (b. April 6, 1986) [Rollo, p. 10].
- Pre-marriage and marital behavior: petitioner observed respondent was introverted, prone to jealousy, lacked ambition, and felt insecure vis-à-vis high-achieving siblings; petitioner noticed jealousy while they were sweethearts and believed respondent might change after marriage [Rollo, pp. 83-84; 91; 92].
- Marital deterioration: respondent’s jealousy intensified; he stalked petitioner, skipped work to follow her, and became possessive and suspicious of anyone who talked to her [Rollo, pp. 85-86].
- Instances of severe behavior: respondent once poked a gun at his 15-year-old cousin who was staying at their house because he suspected the cousin of being petitioner’s lover; in a separate incident in 1986, during a quarrel, respondent poked a gun at petitioner’s head, after which petitioner left with their two daughters and never saw respondent again [Rollo, pp. 85-87].
- Sexual conduct described by petitioner: respondent treated petitioner in a degrading manner—required frequent sexual intercourse (four or five times a day), fetched her during lunch breaks to have sex, tied her to the bed or poked her with things during intercourse, suggested group sex or petitioner having sex with another man in his presence—conduct petitioner described as molestation and maltreatment [Rollo, pp. 85-86].
- Petitioner sought help from a doctor, a lawyer, and a priest and suggested marriage counseling, which respondent refused and dismissed as "kalokohan"; respondent also repeatedly refused treatment and refused to be examined by Dr. Lopez [Rollo, pp. 86-90].
Trial Evidence and Witnesses
- Petitioner testified regarding the facts of the relationship, marital abuse, sexual mistreatment, stalking, and the gun incidents [Rollo, pp. 83-87].
- Expert witness: Dr. Arnulfo V. Lopez, clinical psychologist, conducted an in-depth interview with petitioner, administered psychological tests, and interviewed respondent’s best friend; Dr. Lopez also attempted to invite respondent to participate via registered mail and had limited direct contact with respondent, who declined to engage [Rollo, pp. 87-90; 34-36].
- Dr. Lopez’s clinical findings: he concluded petitioner had emotionally disturbed personality but not a severe mental disorder; he diagnosed respondent with paranoid personality disorder characterized by extreme jealousy, distrust and suspicion, severe doubts about friends and relatives of petitioner, irresponsibility and lack of remorse, resistance to treatment, emotional coldness and immaturity; he opined respondent’s disorder was severe, grave, and incurable and likely hereditary or a result of a pathogenic parental model, noting respondent’s father was a psychiatric patient and positing "double insanity" or psychic contamination [Rollo, pp. 87-90; 36-40].
- Dr. Lopez recommended annulment based on respondent’s incapacity to perform marital obligations; he stated his investigation gathered information from credible informants and psychological tests though he did not personally examine respondent [Rollo, pp. 87-90; 41].
- Summons were served on respondent but he did not appear, and he did not present evidence despite being given a specific date; the trial court deemed his non-appearance a waiver of his right to present evidence [Rollo, pp. 42-45; 90].
Trial Court Findings and Disposition
- RTC credited Dr. Lopez’s findings despite his inability to personally examine respondent, relying on information gathered from credible informants and the totality of observed behavior during cohabitation and marriage [Rol