Wednesday, December 11, 2024

Republic vs. Claur, G.R. No. 246868, February 15, 2022 [Case Digest]

 

Republic vs. Claur,

G.R. No. 246868, February 15, 2022

LAZARO-JAVIER, J.

[Case Digest]

Facts:

            Angelique Pearl sought to have her marriage with Mark declared void ab initio on the ground that they were both psychologically incapacitated. Mark failed to file his answer despite notice.

            Angelique Pearl testified that she and Mark were schoolmates in high school. She had a crush on Mark even though he had a notorious reputation for being flirtatious and for drinking alcohol at such a young age. She got Mark's mobile number from their common friends. Soon after, she became his girlfriend. During their relationship, she discovered that Mark was the "jealous type" and was too obsessed with her. At the same time though, she also found out that Mark was still texting other girls and had been lying to her. Mark also had the habit of not disclosing his whereabouts to her. When Mark tried to break up with her, she threatened to commit suicide. On the other hand, when she would try to break up with him, Mark would devise a way for her to stay in the relationship. He would manipulate her dormmates to convince her not to break up with him. He would also wait outside her dorm and even call her parents. For about three (3) to six (6) months, they alternated between breaking up and reconciling.

            When they went to different universities for college, Mark's jealousy had escalated as well as their fights. They would curse each other and sometimes their quarrels would turn physically violent. During the five (5) years of their boyfriend-girlfriend relationship, they broke up and reconciled around twenty (20) times.

            Then, she got pregnant unexpectedly. She was only twenty (20) years old while Mark was twenty-one (21) years old at that time. When her parents found out, they did not consider marriage as an option. She, too, was hesitant about it. But Mark insisted that they get married. His parents even deceived her by promising that she and Mark would move to the United States of America if she married their son. Thus, on January 3, 2009, they tied the knot at the Ascension Chapel of Villa Escudero. 

            Not long after, she discovered all the lies that Mark fed her. One of them was when Mark made her believe that he was only one (1) semester away from his college graduation. But the truth was, he still needed several years to finish his degree. Another was when Mark told her that his father was working for a certain company. She found out though that Mark's father was a security guard.

            Subsequently, they moved in with her parents in Quezon. Since she was used to their household helper doing chores for her, she did not unpack their things. Mark got irritated and threw the bags at her. She retaliated by hitting him with her "happy feet" clogs. Mark sustained a laceration in the head which bled. He panicked because he feared the sight of blood. But instead of helping Mark, she did not do anything and simply watched him as his head continued to bleed. It was her mother who helped Mark clean the wound and stop the bleeding. She did not tell her mother what happened because she thought her mother would not believe her anyway.

            On April 4, 2009, their son Malique Antonio was born. Mark, nonetheless, wanted to end their relationship. They separated several times, each incident lasting for a few days or a week. Mark had a habit of leaving her and their child to meet up with his friends whenever he got upset. Their married life had been marred by quarrels, disagreements, and even violence. There was one (1) incident when he accidentally locked her up in the bathroom. When she finally got out, she and Mark fought and he hit her in the face, breaking her jaw.

            Dr. Jay Madelon Castillo-Carcereny testified that she is a physician and a psychiatrist. Based on the interviews and tests she conducted; she diagnosed Angelique Pearl with "borderline personality disorder." As for Mark, although she was not able to personally examine him, the information she gathered from Angelique Pearl and Antonio, who personally saw Mark's coping mechanisms when the couple lived with them, was adequate for her to diagnose Mark with "narcissistic personality disorder."

            Dr. Castillo-Carcereny explained that the root cause of their personality disorders was their respective dysfunctional families classified as "double bind" in Mark's case and "pseudo hostility" in Angelique Pearl's case. They had developed it during childhood and had become deeply entrenched in their persons such that neither of them thought they were problems, Any medication or recommended treatment to address the condition would be useless since each of the parties' personality disorder is "grave, permanent and incurable."

            Dr. Castillo-Carcereny recommended that the marriage of Angelique Pearl and Mark be declared void on the basis of each party's "psychological incapacity to perform essential marital obligations which manifested during early adulthood, increasing in gravity and severity from adolescence to present."

            RTC granted the petition for declaration of nullity of Angelique Pearl and Mark's marriage on the ground of both parties' psychological incapacity. It found that the totality of evidence shows that Angelique Pearl and Mark were both psychologically incapacitated to perform their marital obligations.

            On appeal, the OSG argued that the trial court failed to specify the pieces of evidence pertaining to the supposed existence of the parties' psychological incapacity. It argued that Angelique Pearl's statements were "inherently biased and self-serving," Johnson's testimony was "hearsay," and Dr. Castillo-Carcereny's findings were "not credible."

            Court of Appeals affirmed. It held that from the totality of evidence presented, the trial court correctly determined that Angelique Pearl and Mark were both suffering from psychological incapacity characterized by gravity, juridical antecedence, and incurability.

 

Issue:

            Did the evidence on record sufficiently support the petition of Angelique Pearl O. Claur for declaration of nullity of her marriage with Mark A. Claur on ground of psychological incapacity?

 

Held:

            Yes; in the recent case of Tan-Andal v. Andal, the Court clarified that "psychological incapacity" should be understood as a legal concept rather than a medical one. As such, it does not require clinical diagnosis to be established. Ordinary witnesses who have been present in the life of the spouses before the latter contracted marriage may testify on behaviors that they have consistently observed from the supposedly incapacitated spouse.

            Tan-Andal, too, set new parameters in appreciating the three (3) main criteria for psychological incapacity. First, gravity still has to be established, if only to preclude spouses from invoking mild characterological peculiarities, mood changes, occasional emotional outbursts as ground for nullity. Second, incurability should also be understood in the legal sense. So long as the couple's respective personality structures are so incompatible and antagonistic that the only result of the union would be the inevitable breakdown of the marriage, the psychological incapacity of a spouse or both spouses is deemed "incurable". Third, juridical antecedence or the existence of the condition prior to the celebration of marriage, is a statutory requirement which must be proven by the spouse alleging psychological incapacity.

            Tan-Andal likewise decreed that the plaintiff-spouse must prove his or her case by clear and convincing evidence. Notably, this quantum of proof requires more than preponderant evidence but less than proof beyond reasonable doubt. The Court, nonetheless, reiterated that judgments in cases involving the alleged psychological incapacity of a spouse should be based on the totality of evidence adduced during the course of the proceedings. Each case must be resolved based on its particular set of facts and Article 36 of the Family Code applied on a case-to-case basis. For Tan-Andal was not meant to strait-jacket lower courts, forcing them to apply the guidelines in nullity cases of all shapes and sizes.

            In Republic v. Mola Cruz, the Court stressed that the findings of the trial court on the existence or non-existence of a party's psychological incapacity should be final and binding for as long as such findings and evaluation of the testimonies of witnesses and other evidence are not shown to be clearly and manifestly erroneous. A sharper pronouncement on the respect accorded to the trial court's factual findings in the realm of psychological incapacity was made in Kalaw v. Fernandez, “It is not enough reason to ignore the findings and evaluation by the trial court and substitute our own as an appellate tribunal only because the Constitution and the Family Code regard marriage as an inviolable social institution. We have to stress that the fulfilment of the constitutional mandate for the State to protect marriage as an inviolable social institution only relates to a valid marriage. No protection can be accorded to a marriage that is null and void ab initio, because such a marriage has no legal existence.”

Here, the Republic failed to provide compelling reason to convince the Court to deviate from the findings of the trial court, as affirmed by the Court of Appeals. The totality of evidence presented clearly and convincingly show that both Mark and Angelique Pearl are psychologically incapacitated from discharging their respective duties as husband and wife.

           

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