Professional Documents
Culture Documents
DECISION
The decision of the Regional Trial Court, Branch 30, San Jose, Camarines Sur,
dated July 14, 2018, which made final and absolute and that the said marriage was
thereby dissolved.
Petitioner Maria Crisel A. Marpuri and respondent Joseph Royce T. Elpedes were
married at the Office of the Mayor at the Ocampo Municipal Hall, Ocampo, Camarines
Sur on April 29. 2008 (Exh. A).
On February 8, 2017, petitioner filed before the Regional Trial Court, Branch 30,
San Jose, Camarines Sur, a petition seeking the annulment of her marriage to private
respondent on the ground of psychological incapacity of the latter She alleged that from
the time of their marriage up to the time of the filing of the suit, private respondent
abandon her without justifiable cause for more than one year and he failed to perform
his obligation to support the family and contribute to the management of the household.
She averred that private respondent was irresponsible, immature and unprepared for
the duties of a married life.
THE PETITION
Maria Crisel A. Marpuri now comes to us via the present petition to challenge and
seek the reversal of the CA ruling based on the following arguments:
C ralaw1. The Court of Appeals went beyond what the law says, as it totally
disregarded the legal basis of the RTC in declaring the marriage null and void Tuason v.
Tuason (256 SCRA 158; to be accurate, should be Tuason v. Court of Appeals) holds
that "the finding of the Trial Court as to the existence or non-existence of petitioners
psychological incapacity at the time of the marriage is final and binding on us (the
Supreme Court); petitioner has not sufficiently shown that the trial courts factual findings
and evaluation of the testimonies of private respondents witnesses vis-à-vis petitioners
defenses are clearly and manifestly erroneous";
2. Article 36 of the Family Code did not define psychological incapacity; this
omission was intentional to give the courts a wider discretion to interpret the term
without being shackled by statutory parameters. Article 36 though was taken from
Canon 1095 of the New Code of Canon Law, which gives three conditions that would
make a person unable to contract marriage from mental incapacity as follows:
(3) who are not capable of assuming the essential obligations of matrimony due
to causes of a psychic nature."
The decision of the RTC, Maria Crisel A. Marpuri claims, intelligently conforms to
these criteria. The RTC, being clothed with discretionary functions, applied its finding of
psychological incapacity based on existing jurisprudence and the law itself which gave
lower court magistrates enough latitude to define what constitutes psychological
incapacity. On the contrary, she further claims, the OSG relied on generalities without
being specific on why it is opposed to the dissolution of a marriage that actually exists
only in name.chanroblesvirtua|awlibary
SO ORDERED.
LUCAS P. BERSAMIN
Associate Justice
WE CONCUR:
Associate Justice
ROBERTO A. ABAD
MARIANO C. DEL CASTILLO Associate Justice
Associate Justice
Associate Justice
ESTELA M. PERLAS-BERNABE
Associate Justice
ATTE STATI O N
I attest that the conclusions in the above Decision had been reached in
consultation before the case was assigned to the writer of the opinion of the Court's
Division.
Pursuant to Section 13, Article VIII of the Constitution, and the Division Acting
Chairperson's Attestation, I certify that the conclusions in the above Decision had been
reached in consultation before the case was assigned to the writer of the opinion of the
Court's Division.
ANTONIO T. CARPIO
Acting Chief Justice