G.R. No. 242070, August 24, 2020
Jeffrey M. Calma, Petitioner, vs. Mari Kris Santos-Calma, Respondent.

FACTS

Petitioner Jeffrey M. Calma and respondent Mari Kris Santos-Calma met in February 2005. Within a month, they became sexually intimate, and Kris became pregnant. They were married in civil rites on August 15, 2005. Ten days after the marriage, Jeffrey received a visa to work in the Middle East. They agreed Kris would live with Jeffrey’s parents in Pampanga. Kris gave birth to their son on December 31, 2005. Later, Kris moved to her family in Bulacan, then to Jeffrey’s sister’s house in Quezon City due to family misunderstandings. Jeffrey, while abroad, noticed Kris’s escalating monetary demands. In 2008, Kris changed mobile numbers frequently and asked for more money due to being in “deep trouble.” Upon Jeffrey’s return, Kris did not meet him. He found out from her parents that she was cohabiting with another man and was pregnant. Kris showed no remorse and blamed Jeffrey for working abroad. She ceased communication and visits with their son. In 2013, Jeffrey sought to declare the marriage null. Clinical psychologist Dr. Leo Ruben C. Manrique, after interviews, concluded Kris was suffering from schizoid personality disorder, manifested maladaptive behavioral patterns, and was psychologically incapacitated to perform essential marital obligations. Jeffrey filed a Petition for Declaration of Nullity of Marriage. The Guagua Regional Trial Court dismissed the petition, finding a failure to prove the gravity, juridical antecedence, and incurability of Kris’s psychological incapacity, and was dismissive of the expert’s findings. The Court of Appeals affirmed the trial court’s decision.

ISSUE

Whether or not the gravity, juridical antecedence, and incurability of Kris’s psychological incapacity has been shown as would justify the declaration of nullity of her marriage to Jeffrey under Article 36 of the Family Code.

RULING

Yes. The Supreme Court granted the petition and declared the marriage null and void. The Court emphasized that the guidelines in Republic v. Molina should not be applied rigidly as a straitjacket. Psychological incapacity must be viewed on a case-to-case basis, and the totality of evidence must be examined. The Court found that the evidence, including the expert testimony of Dr. Manrique and the factual circumstances, sufficiently established Kris’s psychological incapacity. Her behavior—characterized by infidelity, abandonment of family, lack of remorse, and inability to maintain a stable relationship—manifested a grave and incurable psychological disorder that existed at the time of the marriage (juridical antecedence), rendering her incapable of fulfilling the essential marital obligations of love, respect, fidelity, and mutual support. The Court held that the lower courts erred in strictly requiring a specific medical diagnosis and in disregarding the expert’s findings and the consistent factual narrative. The marriage was declared void ab initio under Article 36 of the Family Code.