FACTS:

Edgar Krohn, Jr. and Ma. Paz Fernandez were married in 1964 and had three children together. However, their relationship became turbulent and they separated in 1973. In 1975, Edgar obtained a confidential psychiatric report on Ma. Paz, prepared by Drs. Cornelio Banaag, Jr. and Baltazar Reyes. Using the report, Edgar obtained a decree nullifying their church marriage in 1978. In 1982, the Court of First Instance granted the dissolution of their conjugal partnership. In 1990, Edgar filed a petition for annulment of their marriage and cited the confidential psychiatric report. Ma. Paz objected to the admission of the report, claiming privileged communication between physician and patient. The trial court admitted the report as evidence, ruling that it was necessary to determine Ma. Paz's alleged psychological incapacity. The trial court also struck off Ma. Paz's statement for the record. Ma. Paz's counsel appealed to the Court of Appeals, but it was dismissed. Ma. Paz then filed a petition for review before the Supreme Court, seeking to enjoin the presentation and disclosure of the report and for her statement to be included in the records. She argued that the prohibition on a physician testifying on privileged matters should also prohibit a third person, like her husband Edgar, from testifying or submitting any medical report acquired through a confidential relationship.

ISSUES:

1. Whether the confidential psychiatric evaluation report is admissible in evidence.

2. Whether the husband can testify on the contents of the report.

RULING:

1. Yes, the confidential psychiatric evaluation report is admissible in evidence. The court ruled that the report is material and relevant to the issue of whether the respondent was suffering from psychological incapacity. The respondent also did not object to the report on the ground of privileged communication between physician and patient, but only argued that it was irrelevant.

2. Yes, the husband can testify on the contents of the report. The court reasoned that since the issue in the case is the respondent's psychological incapacity, the husband, as the petitioner, can testify on the report. The respondent still has the right to dispute the report or cross-examine the husband and the psychiatrist who prepared it.

PRINCIPLES:

• Privileged communication between physician and patient allows for safe and confidential disclosure of information.

• A party can testify on the contents of a confidential report if it is material and relevant to the issue in the case.