Cortez v. Cortez
REITERATIONFacts
The Antecedents: Petitioner Rolando D. Cortez and respondent Luz G. Cortez were married on March 5, 1990. The petitioner filed for annulment of their marriage, alleging psychological incapacity on the part of both himself and the respondent. He claimed their marriage was a result of coercion, as he was allegedly intoxicated and subsequently confronted by the respondent's brother, who insisted he marry her due to her pregnancy. The petitioner further alleged that he was forced to marry the respondent to lift a hold-departure order preventing him from working abroad as a seaman. He asserted that they never consummated their marriage, had no honeymoon, and that he doubted the paternity of their two children, John Rol and Rose Lyn, born during the marriage, especially after discovering the respondent allegedly had another husband and child prior to their union. He also claimed to have undergone a seminal examination revealing low sperm count, rendering him unable to impregnate a woman. Procedural History: The Regional Trial Court (RTC) of Valenzuela City, in its Decision dated July 9, 2012, denied the petitioner's petition for annulment, finding that the evidence did not support his claims of psychological incapacity. The RTC noted evidence suggesting a prior relationship, petitioner's active participation in marriage license application and allotment, attendance at children's baptisms, and intimate pictures of the couple. The petitioner's motion for reconsideration was denied. Subsequently, the petitioner appealed to the Court of Appeals (CA). The CA, in its Decision dated November 5, 2015, affirmed the RTC's ruling, concluding that the totality of facts did not prove psychological incapacity. The CA also denied the petitioner's motion for reconsideration in a Resolution dated May 13, 2016. This led to the present petition for review on certiorari before the Supreme Court. The Petition: Petitioner Rolando D. Cortez filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the decisions of the Court of Appeals. He argues that both he and the respondent are psychologically incapacitated to comply with the essential marital obligations. His primary contention is that he was forced into the marriage due to circumstances beyond his control, leading to a lack of intention and capacity to fulfill his marital duties. He relies on a psychiatric evaluation report by Dr. Felicitas Artiaga-Soriano, which diagnosed him with dependency inclination and passive aggressive personality disorder, and the respondent with anti-social personality disorder, concluding both were psychologically incapacitated. The petitioner seeks to nullify his marriage based on these grounds, asserting that his alleged inability to commit to marital obligations stems from a deep-seated psychological abnormality rooted in his upbringing and the coercive circumstances of his marriage.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's finding that the totality of evidence presented by the petitioner failed to show that either or both parties were psychologically incapacitated to comply with their essential marital obligations. Whether the petitioner's claim of being forced to marry and his subsequent actions constitute psychological incapacity under Article 36 of the Family Code.
Ruling
The petition is denied. The Decision dated November 5, 2015, and the Resolution dated May 13, 2016, of the Court of Appeals in CA-G.R. CV No. 100062 are affirmed.
Ratio Decidendi
On the issue of psychological incapacity: The Court reiterated the established parameters for psychological incapacity under Article 36 of the Family Code, emphasizing that it requires a true inability to commit oneself to the essentials of marriage, not merely difficulty, refusal, or neglect. This incapacity must be grave, juridically antecedent, and incurable. The Court found that the petitioner failed to discharge the burden of proving such incapacity. Evidence presented, such as the postcard, marriage license application, allotment slip, attendance at baptisms, and photographs depicting intimacy, contradicted petitioner's claims of being forced into marriage and lack of cohabitation or sexual intercourse. The Court noted that the alleged acts of psychological disorder occurred after the marriage, and there was no showing of any underlying cause rooted in the parties' childhood or adolescence that would have triggered a disorder. Mere stubbornness, refusal to cohabit, or cohabiting with another woman does not automatically constitute psychological disorder. The Court emphasized that the burden of proving psychological incapacity rests squarely on the petitioner. He must prove that he or the respondent suffered from a psychological disorder that rendered them incapable of taking cognizance of the basic marital obligations. The petitioner failed to meet this burden, as his claims were either unsubstantiated, contradicted by evidence, or did not meet the legal threshold for psychological incapacity. The Court reiterated the doctrine that factual findings of the Court of Appeals, especially when they coincide with those of the RTC, are generally binding on the Supreme Court. The Court is not a trier of facts and will not re-examine or weigh anew the evidence presented by the parties unless the findings are not supported by the evidence on record. In this case, the Court found no reason to deviate from the concurrent findings of the RTC and the CA. On the petitioner's claims of coercion and lack of love, and the psychiatric evaluation: The Court found that the petitioner's claim of being forced to marry and marrying without love does not rise to the level of psychological incapacity that would nullify his marriage. The Court cited jurisprudence holding that marriages entered into for reasons other than love, such as convenience or companionship, are equally valid if they comply with legal requisites. The petitioner's actions, such as making respondent his allottee, attending baptisms, and providing financial support, indicated a commitment to his marital and parental duties, at least initially. His subsequent doubts about paternity and suspension of support, stemming from learning about respondent's prior child, were deemed to be acts of ill-will and refusal, not inherent incapacity. While a psychiatric evaluation was presented, the Court found that it failed to demonstrate how the petitioner's personality traits incapacitated him from complying with essential marital obligations. The report indicated that the petitioner's alleged incapacity stemmed from his lack of intention to fulfill his obligations due to being forced to marry without love, which the Court distinguished from a debilitating psychological condition or illness. Furthermore, the findings regarding the respondent's psychological condition were based solely on information provided by the petitioner, which the Court considered hearsay and unreliable, especially when contradicted by respondent's letters expressing care, love, and a desire to save the marriage.
Main Doctrine
The burden of proving psychological incapacity under Article 36 of the Family Code rests on the petitioner, and mere difficulty, refusal, or neglect in the performance of marital obligations, or ill will, does not amount to psychological incapacity. The alleged incapacity must be grave, juridically antecedent, and incurable.