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AT A GLANCE:
Sometime in 2006, Jeffery, a United States Navy retiree, met Rowena in a bar owner by Rowena’s mother. At that time they started dating, Jeffery knew Rowena had two children from a previous relationship, and Rowena knew Jeffery was married to another, but that his divorce was still pending.
Sometime in 2006, Jeffery, a United States Navy retiree, met Rowena in a bar owner by Rowena’s mother. At that time they started dating, Jeffery knew Rowena had two children from a previous relationship, and Rowena knew Jeffery was married to another, but that his divorce was still pending.
On August 22, 2008, Rowena gave birth to her third child Abigail. Jeffrey acknowledged paternity of Abigail. On May 8, 2010, Jeffery and Rowena got married.
On July 7, 2014, Jeffery filed a Petition for Declaration of Nullity of Marriage with Rowena before the Regional Trial Court of Makati City on the basis of both parties’ psychological incapacity. Aside from documentary evidence proving Rowena’s infidelity, lies, and debts, Jeffery attached a Psychiatric Evaluation Report made by Dr. Ma. Bernadette Manalo-Arcena after conducting interviews with Jeffrey, Rowena, Rowena’s mother, and the spouses’ mutual friend.
The Report summarizes the factual bases for Jeffery’s filing of the petition:
- Rowena had more or less sustained debts worth PhP4 million
- DNA test revealed that Jeffery is not the father of her daughter Abigail
- Jeffery saw photos of his wife with another man hugging, holding hands, and very close together
- Lies with money relationship and activities
- The house which he believed he invested was gone into waste as Rowena mishandled the money for the house
- Rowena had 3 abortions and he found out she was using abortifacient medications
- Dishonesty, lying, cheating and verbal abuse
- Numerous debts and with pathological gambling
- Falsification of their title of the house which he believed initially they owned and paid for but Rowena squandered his money
The RTC granted Jeffery’s petition and ordered the Local Civil Registrars of Makati and Quezon City to record the Decision and cancel the marriage of the parties in their respective Books of Marriages. The CA affirmed the decision of the RTC and held that Jeffery overcame the burden of proving that Rowena is psychologically incapacitated to comply with her essential marital obligations.
Issue: Whether Rowena is psychologically incapacitated to comply with her marital obligations.
The Supreme Court’s Decision: Psychological incapacity consists of clear acts of dysfunctionality that show a lack of understanding and concomitant compliance with one’s essential marital obligations due to psychic causes.
The totality of the evidence presented proved Rowena’s psychological incapacity to comply with her marital obligations. Respondent discharged the burden of proof to establish the psychological incapacity with clear and convincing evidence.
Aside from the Psychiatric Evaluation Report by Dr. Manalo-Arcena, Jeffery attached documentary evidence such as copies of collection cases filed against Rowena, the DNA test result on Abigail’s paternity, and pictures of Rowena hugging and holding hands with another man, in order to prove his allegation of Rowena’s infidelity, lies, and debts. The Report of the parties is further given probative value, since it was offered in evidence and the psychologist conducted a series of standard tests and interviewed Rowena, Jeffery, Rowena’s mother, and their mutual friend.
According to Dr. Manalo-Arcena, Rowena’s personality structure of Borderline Personality Disorder and Antisocial Personality Disorder are characterized and manifested in her frantic efforts to avoid real or imagined abandonment, having unstable relationships with her own mother and Jeffery, unstable self-image, impulsivity, affective instability, and difficulty in controlling anger.
The Report further establishes the gravity, incurability, root cause, and permanence of the parties’ personality structures. According to Dr. Manalo-Arcena, Rowena’s personality structure is a product of problems of trust that existed during the early stages of childhood and her poor parental model figures. Her personality structure is found to be continuing and incurable considering that “the obligations to live together, provide love, give respect, loyalty and fidelity among each other were no longer existent in their marriage. Furthermore, Rowena’s personality with Borderline Personality Disorder and Antisocial Personality Disorder makes it difficult for her to assume essential matiral obligations with Jeffery. Her unstable interpersonal relationship, self-image and emotions, impulsivity, deceitfulness, consistent irresponsibility, and lack of remorse resulted to her refusal to live with Jeffery, they have no fixed family domicile, she lief about Abigail’s paternity, she was a gambler and a spendthrift but was entirely dependent on Jeffery’s support, and she made one lie after another and got deeper and deeper in debt, resulting in civil and criminal cases.
Source:
Rowena Manlutac Green, vs. Jeffery A. Green and the Republic of the Philippines
G.R. No. 255706 | February 17, 2025
SC: Family and Friends’ Testimonies Can Prove Psychological Incapacity in Nullity of Marriage Cases
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