G.R. No. 230222 - People vs. VVV

Case Summary (G.R. No. 230222)

Key Dates and Procedural Posture

Marriage: July 26, 1975.
Petition for nullity filed by respondent: October 21, 1993.
RTC Decision (declaring marriage void ab initio): January 9, 1998.
CA initial Decision (reversing RTC): October 19, 2000.
Supreme Court action directing CA to resolve motion for reconsideration: March 5, 2003.
CA Amended Decision (affirming RTC): November 17, 2003; CA Resolution denying reconsideration: December 13, 2004.
Supreme Court decision under discussion: March 31, 2009 (review on certiorari).

Applicable Law and Doctrinal Sources

Article 36, Family Code: marriage void if at time of celebration one party was psychologically incapacitated to comply with essential marital obligations, even if incapacity becomes manifest only after solemnization.
Relevant jurisprudence and rules discussed: Santos v. Court of Appeals; Republic v. Court of Appeals and Molina (Molina); Edward Kenneth Ngo Te v. Rowena Ong Gutierrez Yu‑Te (Ngo Te); Marcos v. Marcos; Pesca v. Pesca; Antonio v. Reyes; Carating‑Siayngco v. Siayngco; and the Revised Rules on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages (A.M. No. 02‑11‑10‑SC) and its rationale.

Factual Background

The spouses met in medical school (1972) and married in 1975 while respondent was pregnant. They had six children between 1975 and 1991. Benjamin pursued medical specialization and worked at Velez Hospital; Carmen served as hospital treasurer. After years of marriage, Carmen alleged long‑standing misconduct by Benjamin involving regular excessive drinking, violence, sexual coercion, compulsive gambling, financial neglect, and other conduct affecting family life and Benjamin’s professional reliability.

Allegations Forming Basis of Article 36 Claim

Respondent alleged that petitioner: (1) was an alcoholic whose drinking adversely affected family life and profession; (2) exhibited violent tendencies, including physical assault and using a gun to intimidate; (3) engaged in compulsive gambling resulting in sales of assets and pawning of jewelry to pay debts; and (4) was irresponsible and refused to provide regular financial support. She claimed psychological incapacity existing at marriage but becoming manifest later.

Evidence Presented at Trial

Respondent’s evidence included her testimony and testimony of a long‑time nanny corroborating observed maltreatment and petitioner’s patterns of drinking and gambling. She presented Dr. Pureza Trinidad‑Oñate, a psychiatrist, whose evaluation was based on the transcript of petitioner’s deposition and who diagnosed a personality disorder manifested by compulsive drinking, gambling and physical abuse. Petitioner countered with testimony denying psychological incapacity and presented Dr. Renato D. Obra, a psychiatrist, who reviewed the deposition transcript, a South African psychiatric report (Dr. A.J.L. Pentz), and interviewed petitioner’s brothers; Dr. Obra found no personality disorder and emphasized petitioner’s good professional relationships and track record.

Trial Court Ruling

The RTC credited respondent’s evidence and Dr. Oñate’s expert opinion, together with admissions in petitioner’s deposition, and found petitioner psychologically incapacitated to comply with essential marital obligations. The court characterized petitioner as an excessive drinker, compulsive gambler, neglectful of family duties, and prone to violence, concluding these traits had their root in a personality defect existing before the marriage and rendering the marriage void ab initio under Article 36.

Court of Appeals Proceedings and Reconsideration

The CA initially reversed the RTC on October 19, 2000, holding that respondent failed to prove petitioner’s psychological incapacity at the time of marriage and criticizing Dr. Oñate’s conclusion as theoretical rather than based on established facts, invoking the Molina guidelines. After a motion for reconsideration and subsequent Supreme Court resolution directing the CA to resolve that motion, the CA issued an Amended Decision on November 17, 2003, reconsidering itself in light of A.M. No. 02‑11‑10‑SC (the new rules) and affirming the RTC’s declaration of nullity. The CA denied petitioner’s motion for reconsideration in a December 13, 2004 Resolution.

Issues Before the Supreme Court

Whether the CA violated stare decisis by refusing to follow Santos and Molina guidelines.
Whether the CA correctly applied a liberalized standard of proof for psychological incapacity under Article 36.
Whether the CA’s declaration of nullity complied with law and jurisprudence.

Stare Decisis Analysis by the Supreme Court

The Court reiterated the doctrine of stare decisis as a principle requiring lower courts to follow established Supreme Court precedents, rooted in Article 8 of the Civil Code, while recognizing limits and distinctions between vertical and horizontal stare decisis and between constitutional and statutory stare decisis. The Court observed prior holdings that judicial interpretations form part of the law and that overruling may warrant prospective application in narrow circumstances. The decision concluded that the CA’s invocation of Molina and related jurisprudence fell within correct judicial practice and that the CA’s reassessment in light of intervening Supreme Court developments and procedural rule changes was permissible.

On Liberalization of the Proof Requirement under Article 36

The Supreme Court clarified that it had not abandoned Molina but acknowledged subsequent rulings (notably Ngo Te) and the new rules which recognized that the rigid technical requirements in Molina — such as mandatory psychiatric reports attached to the petition and rigid formulas — could operate as a straightjacket and impede access to justice. The Court explained that expert psychiatric evidence is highly advisable and often decisive, but not an absolute condition sine qua non; courts must consider the totality of evidence and may order psychiatric examination during pre‑trial as provided in the revised rules. Where parties had the opportunity to present expert psychiatric testimony tracing root cause, juridical antecedence, gravity and incurability, such expert opinions must be presente

Case Syllabus (G.R. No. 230222)

Procedural History

Petition for review on certiorari filed before the Supreme Court seeking to set aside the Court of Appeals (CA) Amended Decision dated November 17, 2003 and its Resolution dated December 13, 2004 in CA-G.R. CV No. 59903.
The CA’s Amended Decision and Resolution had affirmed the Regional Trial Court (RTC), Branch 23, Cebu City, January 9, 1998 Decision declaring the marriage null and void ab initio under Article 36 of the Family Code.
Judicial timeline highlights:
- Marriage: July 26, 1975.
- Petition for declaration of nullity filed by respondent Carmen: October 21, 1993.
- RTC Decision declaring marriage void: January 9, 1998.
- CA Decision reversing RTC: October 19, 2000.
- Motion for reconsideration, motion practice and certiorari to Supreme Court (docketed G.R. No. 150479) leading to Supreme Court Resolution directing CA to resolve motion for reconsideration: March 5, 2003.
- CA Amended Decision (reconsidering and reversing its October 19, 2000 ruling): November 17, 2003.
- CA Resolution denying Benjamin’s motion for reconsideration: December 13, 2004.
- Supreme Court Decision in G.R. No. 166562 disposing of the petition: March 31, 2009.

Relevant Statute (Article 36, Family Code)

Article 36, Family Code (as amended by Executive Order No. 227 dated July 17, 1987) provides:
- A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations, shall be void even if such incapacity becomes manifest only after solemnization.
The Court addresses standards for proving psychological incapacity under Article 36 and the evidentiary role of psychiatric/psychological expert opinion.

Facts — Parties, Marriage and Family

Parties met in 1972 as medical classmates.
Married on July 26, 1975 in Cebu City while respondent was pregnant with their first child.
Initial residence: petitioner’s family home in Maguikay, Mandaue City; later moved to respondent’s family home in Cebu City after birth of second child.
Petitioner’s professional trajectory:
- Passed medical board examinations in September 1975.
- Entered a residency program for surgery but shifted to anesthesiology after two years.
- Completed preceptorship in anesthesiology by 1979.
- Began working in 1980 as a member of the active staff at Velez Hospital, owned by respondent’s family; respondent served as hospital Treasurer.
- Later worked as an anesthesiologist in a hospital in South Africa.
Children (six): Dennis (b. December 9, 1975); James Louis (b. August 25, 1977); Agnes Irene (b. April 5, 1981); Charles Laurence (b. July 21, 1986); Myles Vincent (b. July 19, 1988); Marie Corinne (b. June 16, 1991).

Respondent’s Allegations — Manifestations of Psychological Incapacity

Carmen alleged petitioner suffered from psychological incapacity that existed at the time of marriage but became manifest later.
Main allegations and manifestations presented:
- Alcoholism: petitioner drank regularly after marriage, returning home late, often drunk and violent; drinking adversely affected family relations and petitioner’s profession.
- Violence and sexual coercion: petitioner allegedly confronted, insulted, physically assaulted respondent and forced her to have sex.
- Use of firearm: instances when petitioner used his gun and shot the gate of their house.
- Professional deterioration: drinking affected petitioner’s work as anesthesiologist; he allegedly refused calls, passed tasks to others, and some surgeons perceived him as unreliable.
- Financial neglect and irresponsibility: deliberate refusal to give financial support; anger at respondent when she asked for money for the children; preference to spend on drinking, gambling and expensive equipment for hobbies.
- Compulsive gambling: petitioner gambled two or three times a week, borrowed money (friends, brothers, loan sharks), pawned respondent’s jewelry to finance gambling; spouses sold the family car twice and a portion of petitioner’s inherited lot to pay gambling debts.
- Banned from casinos in 1986 after causing trouble, an act petitioner later said he did intentionally to be banned.
- Neglect of parental duties: petitioner rarely stayed home and neglected obligations to the children.
Respondent summarized the alleged manifestations as alcoholism, violent nature due to drinking, compulsive gambling leading to asset disposition and debts, and irresponsibility/immaturity as shown in refusal to give regular support.

Petitioner’s Denials and Defenses

Petitioner Benjamin denied psychological incapacity and maintained a respectable reputation among peers.
Claims of social drinking and gambling only for leisure; denial of inherent violent nature except when provoked.
As to financial support allegations:
- Petitioner claimed respondent collected his professional fees from Velez Hospital during his tenure there.
- Insisted he provided financial support within his means and was critical of respondent’s alleged lavish spending.
Petitioner asserted he often comforted and took care of the children and claimed respondent played mahjong twice a week.

Witnesses and Expert Evidence Presented at Trial

Non-expert witness:
- Susana Wasawas, nanny to the spouses’ children (1987–1992): testified to personally witnessing instances when Benjamin maltreated Carmen in front of their children.
Expert witnesses (psychiatrists):
- For respondent: Dr. Pureza Trinidad-Oaate, psychiatrist.
  - Her evaluation was limited to reading the transcript of Benjamin’s deposition (stenographic notes) because Benjamin had gone to work in South Africa.
  - Based on that transcript, Dr. Oaate concluded petitioner’s compulsive drinking, compulsive gambling and physical abuse were clear indications of a personality disorder.
- For petitioner: Dr. Renato D. Obra, psychiatrist and consultant at the Department of Psychiatry, Don Vicente Sotto Memorial Medical Center.
  - Evaluation materials included (a) transcript of stenographic notes of petitioner’s deposition, (b) psychiatric evaluation report by Dr. A.J.L. Pentz, psychiatrist from the University of Pretoria, South Africa, and (c) Dr. Obra’s interview with petitioner’s brothers.
  - Dr. Obra concluded there was nothing wrong with petitioner’s personality, citing petitioner’s good relationship with fellow doctors and his good track record as anesthesiologist.
The two expert psychiatric opinions were diametrically opposed.

Trial Court (RTC) Decision — January 9, 1998

RTC credited Dr. Oaate’s findings and admissions made by petitioner in his deposition.
RTC factual findings:
- Benjamin was psychologically incapacitated to comply with essential obligations of marriage.
- Characterization: excessive drinker, compulsive gambler, person preferring extra-curricular activities to family, and person with violent tendencies.
- RTC found these character traits had a root in a personality defect existing prior to marr