FACTS:
Irene Constantino Datu (Irene) filed a petition seeking the declaration of nullity of her marriage with Alfredo Fabian Datu (Alfredo) on the ground of psychological incapacity. During the trial, Irene testified about Alfredo's delusions and their different religious beliefs, while also admitting that their children were on good terms with their father and received financial support from him. Alfredo presented evidence to prove his schizophrenia, including medical certificates and psychological reports. The trial court found that Alfredo's schizophrenia led to his failure to fulfill his marital obligations and declared the marriage null and void. However, the court found no evidence of juridical antecedence and incurability of Irene's psychological incapacity. Irene filed a Motion for New Trial, which was denied by the trial court.
Irene appealed the trial court's decision, but the Court of Appeals affirmed it, also recognizing Alfredo's schizophrenia. The Court of Appeals rejected Irene's allegations of fraud, collusion, conflict of interest, and the prosecutor's alleged lackadaisical performance. Irene filed a motion for reconsideration, which was also denied by the Court of Appeals. She then filed a Petition for Review on Certiorari before the Supreme Court.
ISSUES:
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Whether or not respondent Alfredo Fabian Datu indeed suffered from schizophrenia.
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Whether or not all the elements of psychological incapacity have been proven by respondent Alfredo Fabian Datu.
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Whether or not the proceedings before the trial court were tainted by fraud, warranting a reversal of the assailed Decision.
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Whether the Supreme Court can review the truthfulness of the allegations and evidence presented in the case.
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Whether Alfredo's schizophrenia automatically makes him psychologically incapacitated to comply with the essential marital obligations.
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Whether Alfredo's psychological incapacity has been sufficiently proven.
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Whether Alfredo's belief that he can have multiple wives and his failure to fulfill his marital obligations constitute psychological incapacity.
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Whether Alfredo's evidence of his psychological incapacity was sufficient.
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Whether there was extrinsic fraud committed by Alfredo to warrant a new trial.
RULING:
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The Petition for Review on Certiorari is denied. The Court held that it is the function of the Court of Appeals to review, evaluate, and weigh the evidence already considered in the trial court. The findings of fact of the Court of Appeals, when supported by evidence, are conclusive on the parties and not reviewable by the Supreme Court. Furthermore, the court also ruled that the factual findings of the trial court, as affirmed by the appellate court, sufficiently established that respondent Alfredo Fabian Datu suffered from schizophrenia and that the elements of psychological incapacity were proven. Lastly, the court found that the allegations of fraud, collusion, and conflict of interest in the proceedings were not substantiated and therefore, did not warrant a reversal of the assailed Decision.
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The Supreme Court is generally bound by the findings of fact of the Court of Appeals, which is a trier of facts. However, there are exceptions to this rule, including when the conclusions are grounded on speculation, manifestly mistaken, based on a misapprehension of facts, conflicting, or contrary to the admissions of both parties. In this case, the Supreme Court finds no reason to review the factual findings of the lower courts as they are the same and sufficiently supported by evidence.
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Psychological incapacity is a legal concept, not a medical one. While suffering from schizophrenia does not automatically make a person psychologically incapacitated, Alfredo's enduring schizophrenia led him to do clear acts of dysfunctionality that undermined the marriage and family. Therefore, he is psychologically incapacitated to comply with the essential marital obligations.
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Alfredo's psychological incapacity has been sufficiently proven through expert testimony and Irene's admission that she receives pension from the Veterans Affairs Office because of his schizophrenia.
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Yes, Alfredo's belief that he can have multiple wives and his failure to fulfill his essential marital obligations constitute psychological incapacity.
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Yes, Alfredo's evidence of his psychological incapacity was sufficient, as supported by the testimony of his wife and the evaluations of the expert witnesses.
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No, there was no evidence of extrinsic fraud committed by Alfredo.
PRINCIPLES:
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The Supreme Court is not a trier of facts and is bound by the findings of fact of the Court of Appeals, when supported by evidence.
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The evidence presented and evaluated by the trial court and affirmed by the appellate court is sufficient to establish the existence of schizophrenia and the elements of psychological incapacity.
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Allegations of fraud, collusion, and conflict of interest must be substantiated with evidence in order to warrant a reversal of a decision.
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The Supreme Court is generally bound by the findings of fact of the Court of Appeals, except in certain exceptions.
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Psychological incapacity is a legal concept, not a medical illness.
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Psychological incapacity must be shown to be a durable or enduring aspect of a person's personality structure that manifests through clear acts of dysfunctionality.
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Psychological incapacity does not have to be incurable but must be permanent relative to a specific partner.
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The incapacity must exist before or during the celebration of the marriage.
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Psychological incapacity as a ground for the declaration of nullity of marriage does not need to be identified as a psychological illness. What is important is the failure to fulfill essential marital obligations due to a genuine psychic cause.
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The required quantum of proof for psychological incapacity is clear and convincing evidence, not beyond reasonable doubt.
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Fraud, as a ground for filing a motion for new trial, refers to a fraud committed by the opponent to prevent the unsuccessful party from fully exhibiting their case in court. Extrinsic fraud may include false promises, compromise, or actions by the opposing party or attorney that prevent full participation in the trial.
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A lawyer's representation of a client does not automatically preclude them from representing another client with adverse interests, unless there is a conflict of interest.
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Conflict of interest exists when the representation of one client will be directly adverse to the interests of another client or when there is a significant risk that the representation of one client will be materially limited by the lawyer's responsibilities to another client.