GR 248569; (January, 2025) (Digest)
G.R. No. 248569 , January 15, 2025
ERICSON C. CABUTAJE, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES AND ROMELIA A. CABUTAJE, RESPONDENTS.
FACTS
Petitioner Ericson C. Cabutaje (Ericson) and respondent Romelia A. Cabutaje (Romelia) were married on January 2, 2003, and had a daughter. Romelia worked abroad in Taiwan, and later in Hong Kong, while Ericson also worked in Taiwan. Their marriage deteriorated, with Romelia becoming inconsistent in providing financial support for their child and eventually entering into another romantic relationship. Ericson filed a petition for declaration of nullity of marriage on the ground of psychological incapacity under Article 36 of the Family Code. The Regional Trial Court (RTC) granted the petition, finding both parties psychologically incapacitated based on the report of clinical psychologist Dr. Nedy Tayag. The RTC’s decision was reversed by the Court of Appeals (CA), which held that Dr. Tayag’s report was insufficient because she did not personally examine Romelia and failed to identify the root causes of the psychological disorders. Ericson filed a Petition for Review on Certiorari before the Supreme Court.
ISSUE
Whether the evidence on record sufficiently supports the petition for declaration of nullity of marriage on the ground of psychological incapacity.
RULING
Yes. The Supreme Court granted the petition, reversing the CA and reinstating the RTC’s declaration of nullity. The Court held that the personal examination of the respondent spouse is not an absolute requirement for proving psychological incapacity. The Court found that Romelia’s psychological incapacity was sufficiently established as grave, incurable, and juridically antecedent. Dr. Tayag’s report, based on interviews with Ericson, his sister, and a mutual friend, diagnosed Romelia with Histrionic Personality Disorder, characterized by pervasive attention-seeking behavior, exaggerated emotions, and seductive conduct, which existed prior to the marriage. Her actions—abandoning her family, failing to provide support, and entering a new relationship—demonstrated a clear inability to comprehend and fulfill the essential marital obligations of mutual love, respect, fidelity, and support. The Court emphasized that the RTC’s factual findings, including its evaluation of expert testimony, are generally accorded respect. Consequently, the marriage between Ericson and Romelia was declared void ab initio under Article 36 of the Family Code.