Love and the law

This is another case of alleged psychological incapacity of a spouse under Article 36 of the Family Code that renders the marriage void from the beginning, if the incapacity is (1) serious such that the party would be incapable of carrying out the ordinary duties required in a marriage, (2) rooted in the history of the party antedating the marriage although it becomes manifest only after the marriage and (3) incurable, or even if it were otherwise, the cure would be beyond the means of the party involved. These are the requirements explained in this case of Rudy and Letty.

Rudy and Letty met during their college years in the United States. They got romantically involved for 15 months and then decided to get married in the Philippines, a year later. Then they returned to the USA and lived with the parents of Rudy where they begot their daughter Lisa, who was their only child born about two years after they got married. While staying with Rudy’s parents, Lisa would always complain of not having enough money as she wanted to live on their own, away from her parents-in-law. She would always nag Rudy to look for a higher paying job in order to get ahead in life and live luxuriously. She only appreciated Rudy when the latter brought her expensive gifts and took her out to fancy and expensive restaurants. Hence Rudy decided to engage in business in order to augment his income.

Then after ten years of living in the USA, Rudy and Letty decided to relocate their business in Korea where Letty’s parents live. But their business failed, so they returned to the Philippines. Like when they were abroad, they always fought about not having enough money. Their constant fighting and Letty’s constant nagging caused humiliation and loss of esteem on the part of Rudy. He even suffered erectile disorder that was ridiculed by Letty, who accused him of having an extra-marital affair.

So after living together for almost 21 years, Letty left Rudy to live in Korea with her parents. Later on she returned to the USA with their daughter Lisa and informed Rudy that she would come back only when he could provide for a better life financially. Such situation prompted Rudy to file a Petition for Declaration of Nullity of their marriage before the Regional Trial Court (RTC), on the ground of psychological incapacity of Letty pursuant to Article 36 of the Family Code.

When Letty failed to file an answer and after determining that no collusion exist between the parties, trial on the merits ensued. Rudy presented Dr. Fred Santos, a clinical psychiatrist who interviewed Rudy, his office secretary Naty and their family driver Berto. Based on these interviews, he concluded that Letty suffers from narcissistic personality disorder because of her dysfunctional familial pattern and psychological development. At age seven her parents separated and she was raised by her mother who was controlling, strict and disciplined by abusing her verbally and spanking her. Her stepfather would also abuse her physically, causing her to be a rebel teenager. Her parents saw money as the key to have a successful life, so she grew up with the main concern in life to have all material things she wanted, and demanding towards the opposite sex. On the other hand, Dr. Santos found that while Rudy was emotionally affected and disturbed by the nature of his marital life, he showed no indication that he too suffers from psychological incapacity.

The RTC dismissed the petition because the totality of the evidence presented was insufficient to establish the gravity and juridical antecedence of Letty’s personality disorder and did not show psychological incapacity on the part of Letty. This ruling was affirmed by the Court of Appeals (CA) which accorded weight and respect on the findings of the RTC. Were the CA and the RTC correct?

Yes, said the Supreme Court (SC). The SC said that while Dr. Santos attributes the gravity of Letty’s personality disorder to the unhealthy childhood, none of the informants whom he interviewed claimed to have known Letty since childhood. Moreover, neither Naty nor Berto appear to have known Letty prior to her marriage. These significantly impair the weight of Dr. Santos’ findings, which are based on their narration of Letty’s childhood events and circumstances which they appear to have no personal knowledge of.

Whether or not psychological incapacity exists in a given case calling for the declaration of nullity of marriage depends crucially on the facts of the case. This Court will not analyze or weigh all over again the evidence or premises of the factual determination of the trial court when affirmed by the CA. They are binding on this Court save for most compelling and cogent reasons like when the findings of the CA go beyond the issues of the case, run contrary to the admissions of the parties to the case, or fail to notice relevant facts which, if properly considered, will justify a different conclusion, or when there is misrepresentation of facts. None of these exceptions is present in this case.

The denial of the present Petition may be viewed as a lifetime sentence trapped in a loveless marriage characterized by failed expectations and lost hopes. But marriage in this jurisdiction stands beyond love or personal emotions. The Court is bound to dispense justice not on the basis of the existence of love or lack thereof but on the basis of law and the evidence on record. The existence of grounds has not been sufficiently shown by the evidence presented in this case (Meneses vs. Meneses, G.R. 200182, March 13, 2019).

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