Republic of the Philippines vs. Angelique Pearl O. Claur and Mark A. Claur,
G.R. No. 246868, February 15, 2022
Facts:
1. Angelique Pearl testified that she and Mark were schoolmates in high school. She had a crush on Mark even though he had a notorious reputation for being flirtatious and for drinking alcohol at such a young age. During their relationship, she discovered that Mark was the "jealous type" and was too obsessed with her. At the same time though, she also found out that Mark was still texting other girls and had been lying to her. When Mark tried to break up with her, she threatened to commit suicide. On the other hand, when she would try to break up with him, Mark would devise a way for her to stay in the relationship.
2. When they went to different universities for college, Mark's jealousy had escalated as well as their fights. They would curse each other and sometimes their quarrels would tum physically violent. During the five (5) years of their boyfriend-girlfriend relationship, they broke up and reconciled around twenty times. Then, she got pregnant unexpectedly. Mark insisted that they get married. They tied the knot. But after the wedding, they only stayed in the house of Mark's family. She had difficulty living with them since she was not accustomed to doing household chores.
3. Not long after, she discovered all the lies that Mark fed her.
4. Subsequently, they moved in with her parents in Quezon. Since she was used to their household helper doing chores for her, she did not unpack their things. Mark got irritated and threw the bags at her. She retaliated by hitting him with her "happy feet" clogs. Mark sustained a laceration in the head which bled. He panicked because he feared the sight of blood. But instead of helping Mark, she did not do anything and simply watched him as his head continued to bleed. It was her mother who helped Mark clean the wound and stop the bleeding.
5. Their son Malique Antonio was born. Mark, nonetheless, wanted to end their relationship. They separated several times, each incident lasting for a few days or a week. Mark had a habit of leaving her and their child to meet up with his friends whenever he got upset. Their married life had been marred by quarrels, disagreements, and even violence. There was one (1) incident when he accidentally locked her up in the bathroom. When she finally got out, she and Mark fought and he hit her in the face, breaking her jaw.
6. When Mark eventually finished college, he made no attempt at all to find gainful employment. He was lazy, extravagant, and given to vices. He refused to find a job and merely relied on her for financial support. Sometime, she insisted that they part ways. Mark retaliated by falsely telling her parents that she had a male text mate and lover.
7. In January 2012, she was expecting to go out on a date with Mark to celebrate their anniversary. Mark, however, came home late and drunk. She then asked their household helper to pack Mark's things. Mark left and they have since been separated in fact.
Issue:
Whether or not the evidence on record sufficiently support the petition of Angelique Pearl 0. Claur for declaration of nullity of her marriage with Mark A. Claur on ground of psychological incapacity.
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Ruling:
Yes. The totality of evidence presented clearly and convincingly show that both Mark and Angelique Pearl are psychologically incapacitated from discharging their respective duties as husband and wife.
First. Their psychological incapacity has juridical antecedence since their personality structures were manifest even before the celebration of their marriage.
Second. The gravity of their condition cannot be categorized as mild characterological peculiarities, mood changes, and mere occasional emotional outbursts. They resented each other and it never failed to manifest each time. Their relationship started from being "rocky", to turbulent, to violent.
Third. Their respective personality structures are "incurable" in the legal sense. Their conditions prevented them from complying with their marital obligations as embodied in the Family Code, particularly the observance of mutual love, respect and fidelity, and rendering mutual help and support.
Fourth. The findings of Dr. Castillo-Carcereny support this conclusion. To emphasize though, Tan-Anda/ categorically declared that the testimony of a medical expert is no longer required for purposes of establishing psychological incapacity as a legal concept. We no longer look at psychological incapacity as a medical condition or personality disorder, the root cause of which has to be identified. Instead, courts may rely on the testimonies of ordinary witnesses for purposes of determining whether one or both spouses are psychologically incapacitated.
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