Case Summary (G.R. No. 214529)
Procedural History at the Regional Trial Court
– November 4, 2010: Petitioner filed a petition for declaration of nullity of marriage under Article 36 of the Family Code, alleging respondent’s psychological incapacity.
– Respondent failed to answer; Public Prosecutor investigated and certified absence of collusion.
– Trial ensued with petitioner and psychologist testifying.
– June 3, 2014: RTC, Branch 14, Baybay City, dismissed the petition for lack of jurisdiction, invoking separation of Church and State and classifying sacramental marriages as purely religious matters.
– August 19, 2014: Reconsideration denied, reiterating that ecclesiastical annulment falls exclusively under Canon Law.
Petition for Civil Nullity: Allegations of Psychological Incapacity
– Petitioner alleged that respondent manifested extreme jealousy, violence, financial extravagance and gambling, resulting in frequent quarrels and physical threats.
– A clinical psychologist diagnosed respondent with “aggressive personality disorder” and “histrionic personality disorder,” rendering her incapable of complying with essential marital obligations under Article 36 of the Family Code.
RTC’s Jurisdictional Ruling Based on Church–State Separation
– RTC held that a marriage solemnized as a Catholic sacrament is governed by Canon Law; civil courts lack power to annul a sacrament.
– Invoked Section 6, Article VI of the 1987 Constitution on separation of Church and State to exclude civil inquiry into the validity of a church marriage.
Denial of Reconsideration
– RTC emphasized constitutional supremacy over the Family Code.
– Reaffirmed that ceremonies and annulments under Church jurisdiction are “per se” religious and beyond civil authority.
Issue on Appeal
Whether the RTC erred in dismissing the petition for lack of jurisdiction over a marriage solemnized in the context of a religious sacrament.
Applicable Constitutional and Statutory Provisions
1987 Constitution
– Article XV, Sections 1–2: Recognizes the family as the foundation of the nation; mandates State protection for marriage as an inviolable social institution.
– Article VI, Section 6: Guarantees separation of Church and State, barring the State from establishing religion or unduly interfering in religious affairs.
Family Code (Executive Order No. 209)
– Article 1: Defines marriage as a special contract governed by law, not subject to stipulation except for property settlements.
– Articles 2–4: Enumerate essential requisites (legal capacity, free consent) and formal requisites (authority of solemnizing officer, marriage license, ceremony with witnesses).
– Articles 7–8: Provide that religious ministers duly authorized and registered may solemnize marriages; permit church solemnization.
– Article 36: Grounds for nullity of marriage on account of psychological incapacity.
Judiciary Reorganization Act (Batas Pambansa Blg. 129)
– Section 19(15): Grants Regional Trial Courts exclusive original jurisdiction over actions involving the contract of marriage and marital relations.
Supreme Court’s Jurisdictional Analysis
– Marriage, though a sacrament in ecclesiastical doctrine, has civil consequences and is regulated by
Case Syllabus (G.R. No. 214529)
Facts
- Petitioner Jerrysus L. Tilar and private respondent were married on June 29, 1996 in a Catholic Church in Poro, Poro Camotes, Cebu, solemnized by Rev. Fr. Vicente Igot.
- They had one son, and the marriage was initially harmonious. Within months, private respondent allegedly developed extreme jealousy and violent tendencies, resulting in quarrels, threats, and physical harm to petitioner.
- Petitioner described private respondent as extravagant, a gambler, and “happy-go-lucky,” and alleged that respondent later lived with another man in Cebu City.
- Petitioner consulted a clinical psychologist who diagnosed private respondent with “aggressive personality disorder” and “histrionic personality disorder,” rendering her psychologically incapacitated to fulfill essential marital obligations under Article 36 of the Family Code.
Procedural History
- On November 4, 2010, petitioner filed a petition for declaration of nullity of marriage before the Regional Trial Court (RTC), Branch 14, Baybay City, under Special Proceeding No. B-10-11-39.
- Private respondent failed to file an answer despite proper service of summons. The RTC ordered the Public Prosecutor to investigate alleged collusion; none was found.
- Trial proceeded with petitioner and his witness testifying.
- On June 3, 2014, the RTC dismissed the petition for lack of jurisdiction over the subject matter, relying on the doctrine of separation of Church and State and deeming church marriage a purely religious sacrament governed by Canon Law.
- Petitioner’s motion for reconsideration was denied on August 19, 2014; the RTC reiterated that church marriages are per se subject only to ecclesiastical jurisdiction.
- Petitioner filed a petition for review on certiorari before the Supreme Court, contending the RTC erred in dismissing a civil petition for nullity of marriag