REPUBLIC v. CESAR ENCELAN

FACTS:

The case involves a petition for review on certiorari filed by the Republic of the Philippines challenging the amended decision of the Court of Appeals (CA) that set aside the decision of the Regional Trial Court (RTC) declaring the marriage between Cesar and Lolita void. Cesar filed a petition with the RTC seeking the nullity of his marriage with Lolita based on her alleged psychological incapacity. Cesar alleged that Lolita had an illicit affair with another man and subsequently abandoned their conjugal home. Cesar presented a psychological evaluation report conducted on Lolita, which found that she had difficulties in maintaining a good and lasting marital relationship. The RTC granted Cesar's petition, but the CA initially set aside the decision, finding that infidelity and abandonment are not sufficient grounds for the declaration of nullity of marriage. However, the CA later amended its decision and affirmed the RTC's ruling, citing Lolita's refusal to perform marital obligations and her abandonment of the conjugal dwelling as indicative of her serious psychological incapacity. The OSG filed the present petition, arguing that Lolita's infidelity and abandonment do not constitute psychological incapacity. The court ruled in favor of the petitioner, stating that there is no sufficient basis to nullify the marriage based on psychological incapacity. The court emphasized that sexual infidelity and abandonment are grounds for legal separation, not for the declaration of nullity of marriage. Cesar failed to prove that Lolita's infidelity and abandonment were manifestations of a disordered personality that prevented her from discharging essential marital obligations. The court also noted that the psychological evaluation report did not establish Lolita's psychological incapacity. Therefore, the court granted the petition, set aside the CA's amended decision, and dismissed Cesar's petition for the declaration of nullity of their marriage.

ISSUES:

  1. Whether there exists sufficient basis to nullify Cesar's marriage to Lolita on the ground of psychological incapacity.

RULING:

  1. The Supreme Court held that there is no sufficient basis to annul Cesar's marriage to Lolita on the ground of psychological incapacity. Cesar failed to prove Lolita's alleged psychological incapacity. Sexual infidelity and abandonment of the conjugal dwelling, even if true, do not necessarily constitute psychological incapacity. It must be shown that these actions are manifestations of a disordered personality that completely prevented the erring spouse from discharging the essential marital obligations. No evidence on record exists to support Cesar's allegation that Lolita's infidelity and abandonment were manifestations of any psychological illness. Moreover, the psychological evaluation report prepared by Dr. Flores did not establish that Lolita suffered from any major psychiatric illness. The observation on Lolita's interpersonal problems with co-workers does not suffice as a consideration for concluding that she was psychologically incapacitated at the time of her marriage. Cesar mistakenly relied on the evaluation report to prove Lolita's psychological incapacity. Therefore, the Court granted the petition, set aside the amended decision of the Court of Appeals, and dismissed Cesar's petition for the declaration of nullity of his marriage to Lolita.