G.R. No. 242362 , April 17, 2024
Leonora O. Dela Cruz-Lanuza, Petitioner, vs. Alfredo M. Lanuza, Jr. and the Republic of the Philippines, Respondents.

FACTS

Petitioner Leonora O. Dela Cruz-Lanuza filed a Petition for Declaration of Nullity of Marriage with the Regional Trial Court (RTC) of Caloocan City against respondent Alfredo M. Lanuza, Jr., based on lack of a valid marriage license and/or psychological incapacity. They were married in June 1984 and have four children. Leonora testified that they did not apply for or secure a marriage license prior to the marriage. She alleged that after a smooth start, Alfredo’s behavior changed: he came home late, neglected his duties, failed to provide for the family, treated her as an ordinary occupant, and engaged in an illicit affair. They separated in 1994, the same year Alfredo married another woman, Mary Ann Makalintal, in Quezon City. Leonora filed a bigamy complaint, which was archived as Alfredo could not be found. Alfredo, a police officer, was dismissed after going AWOL. In 2000, Alfredo married Jane Alejo in Nueva Ecija and later had a church wedding with her. Leonora presented a Philippine Statistics Authority Certification listing three marriage records for “Alfredo Jr. Mares Lanuza” on June 9, 1984 (with Leonora), February 22, 1994 (with Mary Ann Makalintal), and October 16, 2000 (with Jane Alejo). Leonora testified that Alfredo abandoned the family and provided no financial support, visiting the children only once in 1999. A clinical psychologist, Noel N. Ison, evaluated Leonora and concluded, based on interviews with her and other informants (as Alfredo was unavailable), that Alfredo suffered from narcissistic personality disorder with borderline personality traits, rendering him psychologically incapacitated. The RTC denied the petition, finding insufficient evidence of subsequent marriages or psychological incapacity, and doubting the psychologist’s factual basis. Leonora’s motion for reconsideration was denied. She then filed a Petition for Review before the Court of Appeals, which dismissed it for being the wrong remedy (a Rule 42 petition instead of an appeal by certiorari under Rule 45). Leonora elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

The primary issue is whether the Court of Appeals correctly dismissed Leonora’s appeal for being the wrong remedy. A related substantive issue, which the Supreme Court addressed, is whether the totality of evidence presented, including Alfredo’s unjustified prolonged absence and subsequent marriages, establishes his psychological incapacity to comply with essential marital obligations.

RULING

The Supreme Court granted the petition, reversed the Court of Appeals Resolutions, and declared the marriage between Leonora and Alfredo null and void ab initio on the ground of Alfredo’s psychological incapacity. The Court held that the Court of Appeals erred in dismissing the appeal on a technicality, as the rules should be liberally construed to serve substantial justice. On the merits, the Court found that Alfredo’s psychological incapacity was sufficiently proven. His unjustified absence from the marital home for decades, abandonment of his family, failure to provide support, and contracting of multiple subsequent marriages demonstrated a serious personality disorder that was grave, incurable, and existed at the time of the marriage. This pattern of behavior showed a utter insensitivity or inability to give meaning and significance to the marriage. The Court emphasized that while subsequent marriages alone do not prove psychological incapacity, they can be considered as part of the totality of evidence. The psychologist’s report, based on interviews with informed sources, was deemed credible and consistent with the factual circumstances. The Court concluded that Alfredo’s actions manifested a psychological condition that rendered him incapable of fulfilling the essential obligations of marriage.