Javate-Asejo v. Asejo
REITERATIONFacts
The Antecedents: This case concerns a petition for the declaration of absolute nullity of marriage filed by Constancia Javate-Asejo against her husband, Justiniano Zantua Asejo, on the ground of psychological incapacity. Constancia met Justiniano after being widowed and, after a period of courtship, they married in 1989. Their union produced one child, Clifford. Throughout their marriage, Constancia alleged that Justiniano exhibited severe irresponsibility, including a refusal to work, excessive gambling and drinking, verbal and physical abuse towards her, and a general dependence on his family for financial support. These behaviors, according to Constancia, rendered him psychologically incapable of fulfilling his essential marital and parental obligations. Procedural History: The Regional Trial Court (RTC), Branch 21, Santiago City, granted Constancia's petition, declaring the marriage null and void based on Justiniano's psychological incapacity. The RTC found sufficient evidence, including expert testimony from a psychologist who interviewed Constancia and Justiniano's relatives, to support this conclusion. The Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's ruling, holding that the marriage remained valid and subsisting, and that Justiniano's alleged behaviors did not rise to the level of psychological incapacity required by law. Constancia's subsequent motion for reconsideration was denied by the CA, prompting her to file the present petition for review on certiorari with the Supreme Court. The Petition: Constancia Javate-Asejo filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Decision and Resolution of the Court of Appeals. She argues that the CA erred in reversing the RTC's declaration of nullity and in finding that her marriage to Justiniano remains valid. Constancia contends that the totality of evidence, including the expert testimony of Dr. Ethel Maureen Biscarro Pagaddu and the testimonies of other witnesses, clearly and convincingly establishes Justiniano's psychological incapacity. She asserts that this incapacity is characterized by gravity, juridical antecedence, and incurability, as evidenced by his chronic dependence, irresponsibility, and inability to perform his marital duties. Constancia further argues that the CA's reliance on the lack of personal examination of Justiniano by the psychologist is misplaced, as jurisprudence does not mandate such an examination, and that the evidence presented sufficiently demonstrates Justiniano's profound and incurable inability to assume the essential obligations of marriage.
Issue(s)
Did the Court of Appeals err in reversing the Regional Trial Court's declaration of nullity of the marriage between Constancia and Justiniano? Has Constancia adequately established, through evidence including expert testimony, that Justiniano suffers from psychological incapacity?
Ruling
The Supreme Court granted the Petition for Review on Certiorari, reversed the Court of Appeals' Decision and Resolution, and reinstated the Regional Trial Court's Decision declaring the marriage between Constancia Javate-Asejo and Justiniano Zantua Asejo null and void due to Justiniano's psychological incapacity.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in reversing the RTC's declaration of nullity: The Supreme Court held that the CA erred in reversing the RTC's decision. The Court found that the RTC correctly determined Justiniano's psychological incapacity based on the totality of evidence presented. This incapacity was characterized by gravity, juridical antecedence, and incurability, rendering him incapable of performing essential marital obligations. The CA's conclusion that the parties merely had irreconcilable differences and that Justiniano's behavior was mere immaturity or irresponsibility was deemed incompatible with the established facts. The Court also addressed the CA's assessment of evidence, disagreeing that Justiniano's behaviors were insufficient to show psychological incapacity, emphasizing they were external manifestations of a deeper disorder preventing him from fulfilling marital and parental obligations. On the issue of whether Constancia adequately established Justiniano's psychological incapacity: The Supreme Court affirmed that Constancia adequately established Justiniano's psychological incapacity. The Court gave weight to the expert testimony of Dr. Ethel Maureen Biscarro Pagaddu, who traced the root cause of Justiniano's personality disorder to his upbringing. The Court found this disorder was grave, incurable, and had juridical antecedence. The testimonies of other witnesses corroborated Dr. Pagaddu's findings. The Court reiterated that the plaintiff-spouse must prove the case with clear and convincing evidence, which Constancia met. The Court clarified that psychological incapacity refers to a malady so grave and permanent as to deprive one of awareness of marital duties, finding Justiniano's over-reliance and inability to understand his responsibility demonstrated this incapacity.
Main Doctrine
The Supreme Court reinstated the RTC's declaration of nullity of marriage due to the husband's psychological incapacity, finding that the evidence presented, including expert testimony and corroborating witnesses, met the clear and convincing standard of proof, establishing the gravity, juridical antecedence, and incurability of the incapacity.