8. Republic v. CA.docx - 8 Title Republic v CA G.R No 159594 Name of Digester Geronilla Date November 12 2012 Ponente Bersamin J Subject Syllabus Topic

8. Republic v. CA.docx - 8 Title Republic v CA G.R No...

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8. Title: Republic v. CAName of Digester: GeronillaG.R. No. 159594Date: November 12,2012Ponente: Bersamin, J. Subject / Syllabus Topic: Void Marriages: Procedure in actions for declaration of nullity:Safeguards against collusionDoctrine: Santos v. Court of Appeals, 240 SCRA 20 (1995) – Court decreed that psychological incapacityshould refer to a mental incapacity that causes a party to be truly incognitive of the basic maritalcovenants such as those enumerated in Article 68 of the Family Code and must be characterized bygravity, juridical antecedence and incurability.Republic v. CA (Molina), 268 SCRA 198 (1997) - the Court established guidelines involving thenullity of marriage based on the ground of psychological incapacity. These eight (8) guidelines werenot met in the instant case since the gravity; root cause and incurability of Catalina's purportedpsychological incapacity were not sufficiently established.Suazo v. Suazo, 615 SCRA 154 (2010) – the Court held that there must be proof a natal orsupervening disabling factor that effectively incapacitated the respondent from complying with thebasic marital obligations.Petitioner: Republic of the PhilippinesRespondent: Hon. Court of Appeals (NinthDivision) and Eduardo C. De Quintos, Jr.Facts: Antecedents:Eduardo and Catalina were married on March 16, 1977 in civil rites solemnized by the Municipal Mayorof Lingayen, Pangasinan.The couple was not blessed with a child due to Catalina’s hysterectomy following her secondmiscarriage.On April 6, 1998, Eduardo filed a petition for declaration of nullity of marriage citing Catalina’spsychological incapacity to comply with her essential marital obligations as a ground. Catalina did not interpose any objection to the petition, but prayed that she be given her share in theconjugal house and lot in Bacabac, Bugallon, Pangasinan.After conducting an investigation, the public prosecutor determined that there was no collusionbetween Eduardo and Catalina.Eduardo alleged that Catalina always left the house without his consent; that she engaged in pettyarguments with him; that Catalina constantly refused to give in to his sexual needs; that she spentmost of her time gossiping with neighbors instead of caring for their adopted daughter; that shegambled away all his remittances as an overseas worker in Qatar since 1993; and that she abandonedthe conjugal home in 1997 to live with her paramour, Bobbie Castro.To support his claim, he presented the results of a neuro-psychiatric evaluation conducted by Dr.Annabelle Reyes stating that Catalina exhibited traits of a Borderline Personality Disorder that was nolonger treatable.Dr. Reyes found that Catalina’s disorder was mainly characterized by her immaturity that rendered herpsychologically incapacitated to meet her marital obligation.Catalina did not appear during trial but admitted her psychological incapacity. However, she deniedflirting with different men and abandoning the conjugal home.
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