Case Digest: So v. Republic (G.R. No. 170603)

So v. Republic | G.R. No. 170603 | 29 Jan 2007 | Callejo, Sr. J. | Art IV (Section 1, Par 4) | Petitioners: Edison So Respondents: Republic of the Philippines Recit Ready Summary Herein Petitioner So filed for a Petition for Naturalization under CA No. 473 aka the Revised Naturalization Law.He presented 2 witnesses à fam business lawyer Atty. Adasa & UST classmate Mark Salcedo. RTC granted So’s petition. Respondent Republic of the Phil through OSG said not so fast! Coz SolGen claims na the 2 witnesses So presented did not know him (So) well enough and that they only gave general statements upon being asked about the character and moral conduct of So. CA set aside RTC’s decision. Hence, this present petition. The issue is W/N So qualifies for Philippines Citizenship and the Court said NO. It was wrong for So to claim that that RA 9139 should apply to his case instead of CA No. 473. This is because the latter applied to ALL ALIENS regardless of class while the former applies to nati...
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Case Digest: Maria Dela Fuente v. Rodolfo Dela Fuente (G.R. No 188400)

Maria Dela Fuente v. Rodolfo Dela Fuente | GR. No. 188400 | March 8, 2017  Psychological incapacity |

FACTS:

  • Petitioner Maria and Rodolfo met while they were still students at the University of Sto. Tomas. Maria observed that Rodolfo was introvert, prone to jealousy, and did not have any ambition in life because of his insecurity towards his siblings who were successful in their careers. 
  • On June 21, 1984, they got married and eventually had two children During their marriage, Rodolfo’s attitude worsened. He was suspicious of his wife and even resorted to stalking just to confirm if she was having an affair with another man. He even poked a gun to his 15-year old cousin who he suspected was Maria’s lover. Maria also alleged that she was Rodolfo’s sex slave. That they had sex five times a day. Rodolfo would even fetch her from the office during lunch break just to have sex. It bothered her that her husband even suggested to invite another man to share their bed.
  • She asked the advice of different people in order to fix their marriage, but Rodolfo was not keen to undergo marriage counseling. It was in 1986 when Maria and her children left their family home because Rodolfo poled a gun to her head after they had an argument.
  • On June 3, 1999, Maria filed a petition for declaration of nullity of marriage before the RTC of Quezon City. Maria’s counsel presented Dr. Lopez as their expert witness. Dr. Lopez said that Maria was not suffering from any severe mental disorder but she had an emotionally disturbed personality which is not severe enough to constitute psychological incapacity. On the other hand, Dr. Lopez diagnosed Rodolfo with paranoid personality disorder which was caused by pathogenic parental model- that his family background showed that his father was a psychiatric patient. Therefore, his disorder was serious and incurable.
  • The RTC rendered its decision on June 26, 2002 granting the petition for declaration of nullity of marriage. They opined that while Dr. Lopez was not able to personally examine Rodolfo, the findings based on information from credible informants were enough. After the RTC denied OSG’s motion for reconsideration, the latter appealed to the CA. CA granted the appeal and reversed the decision of the RTC. They ruled that the testimony of Dr. Lopez was unreliable for being hearsay. 

ISSUE: W/N the CA erred in denying the petition for declaration of nullity of marriage because the evidence was insufficient to prove that Rodolfo was psychologically incapacitated

RULING:          

  • The Supreme Court ruled that there was sufficient compliance with the Molina doctrine to warrant the nullity of petitioner Maria De la Fuente’s marriage. The CA argued that the RTC should not have given weight to the findings of Dr. Lopez since he failed to personally conduct a thorough study of Respondent’s psychological and mental condition. However, as ruled by the SC in previous cases like Camacho-Reyes v. Reyes, “the non-examination of one of the parties will not automatically render as hearsay or invalidate the findings of the examining psychiatrist or psychologist… the totality of the behavior of one spouse during the cohabitation and marriage is generally and genuinely witnessed mainly by the other.”
  • The testimony of Dr. Lopez with the corroboration of the petitioner proved that respondent has psychological incapacity. The root cause of his paranoid personality was hereditary since his own father suffered from a similar disorder. It started during his late childhood years and progressed as he reached his adolescent years. 
  • His paranoid personality made him prone to extreme jealousy and resort to stalking. That led to his incapacity to do his obligations in the marriage. Furthermore, the respondent exercised coercive control over his wife. The respondent harassed the petitioner in order to intimidate and dominate her. At first, he employed non-physical forms of mistreatment which eventually led to physical violence. 
  • For the aforesaid reasons, the Supreme Court reversed the decision of the Court of Appeals and reinstated the decision of the RTC declaring the nullity of marriage of Maria De La Fuente.

 PETITION GRANTED

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