G.R. No. 259322, August 06, 2025
NELLIE Y. CHAN TEE TEN, PETITIONER, vs. WILLY Q. TEE TEN AND THE REPUBLIC OF THE PHILIPPINES, RESPONDENTS.

FACTS

Willy Q. Tee Ten filed a petition for the declaration of nullity of his marriage to Nellie Y. Chan Tee Ten on the ground of her psychological incapacity under Article 36 of the Family Code. He alleged that Nellie’s incapacity, rooted in a childhood of overindulgence, manifested before and after their 1995 marriage through a domineering and controlling attitude, arrogance towards his family, irrational accusations of an incestuous relationship with his mother, verbal and physical abuse, and psychological abuse of their children. A clinical psychologist, Dr. Natividad A. Dayan, diagnosed Nellie with Narcissistic Personality Disorder with paranoid features, concluding her incapacity was grave, incurable, and antecedent. Nellie countered that Willy was the abusive party, alleging physical, sexual, and psychological abuse, and challenged the psychological report’s reliability as it was based solely on interviews with Willy and his witnesses, as she herself refused to be examined. The Regional Trial Court (RTC) granted the petition and declared the marriage void. The Court of Appeals (CA) affirmed the RTC ruling, holding that the psychological report and testimonies sufficiently proved Nellie’s psychological incapacity, and that the report retained probative value despite the lack of personal examination of Nellie due to her refusal. Nellie filed a Petition for Review on Certiorari, arguing the CA erred in relying on the psychological report, disregarding her allegations of abuse by Willy, and not finding Willy psychologically incapacitated or in bad faith. She also prayed for an increase in support pendente lite.

ISSUE

Whether the lower courts correctly declared the marriage of the parties void on the ground of Nellie’s psychological incapacity under Article 36 of the Family Code.

RULING

The Petition is without merit. The Supreme Court affirmed the lower courts’ decisions. The core issue raised by Nellie is factual in nature, and in a Rule 45 proceeding, the Court’s jurisdiction is limited to reviewing errors of law, not re-examining factual findings. The factual findings of the RTC, affirmed by the CA, are generally conclusive. The CA correctly held that the psychological report of Dr. Dayan, coupled with the testimonies of Willy and his witnesses, sufficiently established the juridical antecedence, gravity, and incurability of Nellie’s psychological incapacity. The report did not lose its probative value even without a personal examination of Nellie, as it was she who refused to be examined. The Court found no reversible error in the CA’s judgment.