G.R. No. 214392 , December 07, 2022
Sue Ann Bounsit-Torralba, Petitioner, vs. Joseph B. Torralba, Respondent, Republic of the Philippines, Oppositor-Respondent.

FACTS

Petitioner Sue Ann Bounsit-Torralba and respondent Joseph B. Torralba were married on January 26, 1996, in Pinamungajan, Cebu, without a marriage license. They first met in 1989, began a relationship in December 1995, and entered into a hasty civil marriage because Joseph, a seaman, was in a hurry to report for work abroad. During the marriage, Joseph exhibited irresponsible behavior, including gambling, drinking, substance use, womanizing, and drug trafficking, which led to his disembarkation from work in 2000. He showed no love or respect for Sue Ann, was often absent from home, and humiliated her. In October 2001, Sue Ann left for Dubai to support their family, and in December 2001, Joseph left after their daughter’s first birthday, with no further contact. On August 8, 2007, Sue Ann filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) on the ground of Joseph’s psychological incapacity under Article 36 of the Family Code and the lack of a marriage license. Joseph did not file an Answer or participate in the trial. Sue Ann presented herself, her niece Verlain Bounsit, and clinical psychologist Maryjun Y. Delgado as witnesses. Delgado, after interviewing Sue Ann and Verlain, concluded that Joseph suffered from Anti-Social Personality Disorder, rooted in dysfunctional upbringing, which rendered him psychologically incapacitated to fulfill marital obligations. The RTC granted the petition, declaring the marriage null and void. The Republic, through the Office of the Solicitor General (OSG), appealed. The Court of Appeals (CA) reversed the RTC, declaring the marriage valid and subsisting, without ruling on the issue of the lack of a marriage license. Sue Ann’s motion for reconsideration was denied.

ISSUE

1. Whether the CA erred in reversing the RTC’s decision despite evidence supporting the finding of Joseph’s psychological incapacity.
2. Whether the CA committed grave abuse of discretion in refusing to rule on the validity of the marriage based on the absence of a valid marriage license.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the CA Decision and Resolution, and REINSTATED the RTC Decision declaring the marriage null and void.
1. On Psychological Incapacity: The Supreme Court held that Sue Ann failed to establish Joseph’s psychological incapacity by clear and convincing evidence. The psychological evaluation was based solely on interviews with Sue Ann and her niece, without personal examination of Joseph, making it insufficient to prove a grave, severe, and incurable psychological disorder existing at the time of the marriage. The behaviors described (gambling, drinking, womanizing, irresponsibility) constituted mere difficulty, refusal, or neglect in performing marital obligations, not psychological incapacity as defined in Santos v. CA and Republic v. Molina.
2. On Lack of Marriage License: The Supreme Court ruled that the marriage was null and void due to the absence of a marriage license, which is an essential requisite for a valid marriage under Article 3 of the Family Code. It was established that the marriage was celebrated without a license. The exemption under Article 34, which allows a marriage without a license if the parties have cohabited for at least five years, did not apply because Sue Ann testified that they never cohabited as husband and wife before the marriage. This fact was uncontested, as Joseph did not participate in the proceedings. The CA’s refusal to rule on this issue, despite it being raised, constituted an error. The Court emphasized that the absence of a marriage license is a jurisdictional matter that can be raised at any time and renders a marriage void from the beginning. Thus, the marriage was declared null and void ab initio.