Facts:
Constancia Javate-Asejo, a widow who was befriended and later on assisted by Justiniano Zantua Asejo in processing her pension benefits, became close with him leading to a “mutual understanding.” Discovering his unsustainable lifestyle with his family, she was impelled by her pregnancy and her parents to marry him on December 23, 1989. The marriage was marred by Justiniano’s refusal to seek employment, dependency on both their families, and engagement in gambling and substance abuse.
Constancia had to work abroad and later in a private firm to support their child, Clifford, born on April 1, 1990. Justiniano’s behavior worsened as he abused Constancia physically and verbally, compelling her to labor like a Guest Relations Officer during his drinking sprees, and neglected to shoulder family responsibilities.
After a tumultuous relationship and incidents of public humiliation, Constancia left Justiniano in 1996 and eventually took custody of Clifford. On September 9, 2013, she filed a Petition for Declaration of Absolute Nullity of Marriage under Article 36 of the Family Code, arguing Justiniano’s psychological incapacity. The Regional Trial Court (RTC) granted the petition, but the Court of Appeals (CA) reversed this, holding the marriage as valid and subsisting, prompting Constancia to file a Petition for Review on Certiorari before the Supreme Court.
Issues:
1. Whether the CA erred in not recognizing the psychological incapacity of Justiniano Zantua Asejo and reversing the RTC’s decision.
2. Whether expert testimony, based on interviews with collateral relatives, suffices in establishing psychological incapacity.
3. Whether repeated irresponsibility, dependence, substance abuse, and refusal to seek employment constitute psychological incapacity.
4. Whether the evidence provided meets the standard of clear and convincing evidence required to prove psychological incapacity.
Court’s Decision:
The Supreme Court granted Constancia’s petition and reinstated the RTC’s decision, declaring the marriage null and void due to Justiniano’s psychological incapacity. Contrary to the CA’s findings, the Court concluded Justiniano’s incapacity was characterized by:
– Gravity: The incapacity severely impacted Justiniano’s functioning as a spouse.
– Juridical Antecedence: It existed prior to and during the marriage.
– Incurability: It was permanent and deeply ingrained in Justiniano’s personality.
The expert testimony by Dr. Pagaddu, the corroborating witnesses, and Justiniano’s lack of participation in the proceedings established clear and convincing evidence. The Court rebuffed the CA’s characterization of mere irresponsibility and immaturity, asserting a deeper, pervasive psychological condition impeding Justiniano from fulfilling marital duties.
Doctrine:
The doctrine established is that psychological incapacity involves a person’s inability to comprehend and fulfill the basic marital obligations, not just mere refusal, neglect, or ill will. The incapacity must exhibit gravity, antecedence, and incurability, and clear and convincing evidence is required to establish it.
Historical Background:
This case reflects the application of Article 36 of the Family Code of the Philippines, which allows for the annulment of a marriage on the ground of psychological incapacity. The Supreme Court’s decision emphasizes the need for a nuanced understanding of psychological incapacity beyond mere behavioral deficiencies and promotes the gender-sensitive interpretation of marital obligations, reflecting progress in social and judicial perspectives on gender roles, marriage, and responsibilities within family dynamics.
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