Egmalis-Ke-Eg v. Republic
REITERATIONFacts
The Antecedents: The underlying dispute concerns a petition for the declaration of nullity of marriage filed by Aida Egmalis-Ke-eg against her husband, Ireneo Ke-eg, under Article 36 of the Family Code. Aida alleged that Ireneo was psychologically incapacitated to fulfill his essential marital obligations. The couple, belonging to the Kankana-ey Tribe, were married on January 18, 1983, under community pressure due to Aida's pregnancy. The petition detailed Ireneo's alleged irresponsibility, including his preference for drinking over employment, his failure to provide support for Aida and their son, Kurk, and his alleged involvement in a murder case. Aida worked abroad for extended periods to support the family, while Ireneo remained absent and unsupportive. A psychologist testified, diagnosing both parties with personality disorders, concluding they were psychologically incapacitated to assume marital obligations. Procedural History: The Regional Trial Court (RTC), Branch 30, City of San Fernando, La Union, declared the marriage null and void ab initio due to the psychological incapacity of both Aida and Ireneo. The RTC favored the psychologist's findings. The Office of the Solicitor General (OSG) filed a motion for reconsideration, which the RTC denied. The OSG then appealed to the Court of Appeals (CA). The CA, in its Decision dated October 29, 2018, reversed the RTC's ruling, finding insufficient evidence to establish Ireneo's psychological incapacity and noting that Aida's psychological incapacity was not averred in her petition. The CA denied Aida's subsequent motion for reconsideration in a Resolution dated July 24, 2019. The Petition: Petitioner Aida Egmalis-Ke-eg filed a Petition for Review under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. The petition raises two main issues: (1) whether the marriage is null and void ab initio due to the psychological incapacity of either or both parties, and (2) whether the RTC could grant a relief not prayed for in the petition, specifically the declaration of Aida's psychological incapacity. The petitioner argues that Ireneo's persistent irresponsibility, habitual drinking, lack of support, and failure to fulfill marital duties, as supported by her testimony, her sister's testimony, and expert psychological evaluation, demonstrate his psychological incapacity. She contends that the CA erred in reversing the RTC's finding of nullity based on Ireneo's incapacity.
Issue(s)
WHETHER THE MARRIAGE BETWEEN AIDA AND IRENEO IS NULL AND VOID AB INITIO ON THE GROUND OF THE PSYCHOLOGICAL INCAPACITY OF EITHER OR BOTH OF THEM TO COMPLY WITH THE ESSENTIAL OBLIGATIONS OF MARRIAGE; WHETHER THE RTC MAY GRANT A RELIEF NOT PRAYED FOR IN THE PETITION, i.e., THE DECLARATION OF AIDA'S PSYCHOLOGICAL INCAPACITY TO COMPLY WITH HER ESSENTIAL MARITAL OBLIGATIONS.
Ruling
The petition is GRANTED. The Decision dated October 29, 2018 and the Resolution dated July 24, 2019 of the Court of Appeals in CA-G.R. CV No. 108998 are REVERSED and SET ASIDE. The marriage between petitioner Aida Egmalis-Ke-eg and Ireneo Ke-eg is declared null and void ab initio.
Ratio Decidendi
On the issue of Ireneo's psychological incapacity: The Court found that the totality of evidence clearly and convincingly showed Ireneo's psychological incapacity to fulfill the essential obligations of marriage, as defined in Articles 68 to 71 and 220, 221, and 225 of the Family Code. These obligations include living together, mutual love, respect, fidelity, and rendering mutual help and support. The marriage began under duress due to Aida's pregnancy and community pressure, not free will. Ireneo's persistent irresponsibility, habitual drinking, lack of employment, failure to support his family, verbal and emotional abuse, and alleged involvement in a murder case demonstrated a profound disregard for his marital duties. His psychological condition, diagnosed as Antisocial Personality Disorder, was found to be grave, with juridical antecedence (existing before marriage), and incurable in the legal sense, making him unable to understand or comply with his essential marital obligations. The testimony of Aida's sister corroborated these findings, painting a consistent picture of Ireneo's dysfunctionality. On the issue of the RTC granting relief not prayed for: The Court held that the RTC may not grant a relief not prayed for in the pleadings or in excess of what is sought by a party, citing due process considerations. While a general prayer for "other reliefs just and equitable" can justify awarding reliefs not specifically prayed for, this rule should not apply in cases for declaration of nullity of marriage under Article 36 of the Family Code, where psychological incapacity must be proven by clear and convincing evidence. Doubts are resolved in favor of the marriage's validity. Therefore, the RTC erred in declaring Aida psychologically incapacitated when it was not sufficiently averred or proven by clear and convincing evidence. The Court further found that Aida, unlike Ireneo, did not exhibit psychological incapacity; she actively contributed to the family's support and education of their son despite Ireneo's failings.
Main Doctrine
The marriage between Aida Egmalis-Ke-eg and Ireneo Ke-eg is declared null and void ab initio due to Ireneo's psychological incapacity to comply with the essential obligations of marriage, as evidenced by his persistent irresponsibility, disregard for social norms, impulsiveness, and failure to provide support, which are rooted in his personality structure and render him incapable of fulfilling marital duties.