Green v. Green
REITERATIONFacts
The Antecedents: This case concerns the psychological incapacity of Rowena Manlutac Green as a ground for the declaration of nullity of her marriage to Jeffery A. Green. The parties met in 2006, and despite Jeffery being married and Rowena having two children from a previous relationship, they developed a relationship. Rowena gave birth to Abigail in 2008, with Jeffery acknowledging paternity. They married in 2010. Jeffery worked in Makati City, while Rowena divided her time between Makati and Angeles City where her other children resided. The underlying dispute centers on allegations of Rowena's infidelity, dishonesty, significant debts, gambling, and mishandling of finances, which Jeffery claims demonstrate her psychological incapacity to fulfill her marital obligations. Procedural History: Jeffery A. Green filed a Petition for Declaration of Nullity of Marriage with the Regional Trial Court (RTC) of Makati City on July 7, 2014, citing both parties' psychological incapacity under Article 36 of the Family Code. Rowena failed to file an answer, and the Office of the Solicitor General found no collusion. The RTC granted the petition on June 5, 2017, declaring the marriage void ab initio due to Rowena's psychological incapacity, specifically diagnosed as Borderline Personality Disorder and Antisocial Personality Disorder. Rowena's motion for reconsideration was denied. She appealed to the Court of Appeals (CA), which affirmed the RTC's decision on June 30, 2020, and denied her subsequent motion for reconsideration on January 29, 2021. The CA found that Jeffery had sufficiently proven Rowena's psychological incapacity. The Petition: Rowena Manlutac Green filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. She argues that the CA manifestly overlooked or misconstrued relevant facts and that its findings were not supported by the evidence. Specifically, she questions the weight given to the psychological evaluation report by Dr. Ma. Bernadette Manalo-Arcena, asserting that the testimony based on her mother's statements should not be credited, that the doctor lacked sufficient reliable information, and that her debts alone should not be a basis for nullity. Rowena also contends there was no proof of her infidelity, that Jeffery knew Abigail was not his child, and that her living arrangements were a way to shield her husband from issues concerning her other children, demonstrating her awareness of marital obligations. She seeks to preserve her marriage, asserting that Jeffery failed to prove the grounds for nullity.
Issue(s)
Whether petitioner Rowena Manlutac-Green is psychologically incapacitated to comply with her marital obligations, making her marriage with respondent Jeffery A. Green void under Article 36 of the Family Code.
Ruling
The Petition is DENIED. The June 30, 2020 Decision and January 29, 2021 Resolution of the Court of Appeals in CA-G.R. CV No. 109677 are AFFIRMED, declaring the marriage between Rowena Manlutac-Green and Jeffery A. Green void ab initio.
Ratio Decidendi
On the issue of psychological incapacity under Article 36 of the Family Code: The Court affirmed the declaration of nullity of marriage, finding that Rowena Manlutac-Green was psychologically incapacitated to comply with her essential marital obligations. The Court reiterated the guidelines established in Tan-Andal v. Andal, emphasizing that psychological incapacity consists of clear acts of dysfunctionality stemming from psychic causes that undermine the family and show a lack of understanding and compliance with marital obligations. While expert opinion is no longer strictly required, the Psychiatric Evaluation Report by Dr. Manalo-Arcena, based on interviews with Rowena, Jeffery, Rowena's mother, and a mutual friend, was given probative value. The report diagnosed Rowena with Borderline Personality Disorder and Antisocial Personality Disorder, characterized by frantic efforts to avoid abandonment, unstable relationships, unstable self-image, impulsivity, affective instability, difficulty controlling anger, deceitfulness, irresponsibility, and lack of remorse. These personality traits manifested in her actions, including significant debts, gambling, financial irresponsibility, manipulation of Jeffery for money, deception regarding Abigail's paternity, infidelity, and involvement in civil and criminal cases. The Court found these behaviors to be more than mere characterological peculiarities, constituting a grave and incurable incapacity rooted in her personality structure, which existed prior to the marriage and made it impossible for her to fulfill her marital duties. The totality of evidence, including documentary proof of debts, DNA test results, and pictures of infidelity, corroborated the psychologist's findings and established the psychological incapacity with clear and convincing evidence, thus justifying the declaration of nullity of marriage.
Main Doctrine
Psychological incapacity, as contemplated in Article 36 of the Family Code, 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. It is not a medical illness that has to be medically or clinically identified, and expert opinion is not required, though it may be given weight if offered in evidence. The incapacity must be shown to have existed at the time of the celebration of the marriage, be caused by a durable aspect of one's personality structure formed before marriage, and be genuinely serious.