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      Annulment Main

 

     
     
 

SUPREME COURT DECISIONS: ANNULMENT AND OTHER RELATED TOPICS

 
 

October 27, 2004

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JUANITA CARATING-SIAYNGCO versus MANUEL SIAYNGCO G.R. 158896. 

 

"Irreconcilable differences” and “conflicting personalities of the husband and wife do not constitute psychological incapacity. Manuel Siayngco is a Judge of a Municipal Trial Court. He filed a Petition to declare his marriage void on the ground of psychological incapacity of his wife. According to him, all throughout their marriage, his wife exhibited an over domineering and selfish attitude towards him which was exacerbated by her extremely volatile and bellicose nature; that she incessantly complained about almost everything and anyone connected with him like his elderly parents, the staff in his office and anything not of her liking like the physical arrangement, tables, chairs, wastebaskets in his office and with other trivial matters; that she showed no respect or regard at all for the prestige and high position of his office as judge of the Municipal Trial Court; that she would yell and scream at him and throw objects around the house within the hearing of their neighbors; that she cared even less about his professional advancement as she did not even give him moral support and encouragement But his wife Juanita disagreed and contested the Petition. She also presented her own expert testimony - a psychiatrist. The psychiatrist basically told the Court that Juanita is not psychologically incapacitated, contrary to the earlier testimony of Manuel's testimony.  

 

According to the Supreme Court, Manuel Siayngco's situation is perceived to be a simple case of a married couple drifting apart, becoming strangers to each other, with the husband consequently falling out of love and wanting a way out.  The Supreme Court further states that "an unsatisfactory marriage, is not a null and void marriage. Mere showing of “irreconcilable differences” and “conflicting personalities” in no wise constitutes psychological incapacity. Petition is denied.

 

March 03, 2004

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MARIETTA B. ANCHETA versus RODOLFO S. ANCHETA, G.R. No. 145370.

 

Questionable annulment proceedings in the Regional Trial Court. In this case, Rodolfo Ancheta filed a Petition on June 5, 1995 before the Regional Trial Court of Naic, Cavite, Philippines in order to declare his marriage void on the ground of psychological incapacity. A month thereafter or on July 7, 1995, the Court issued an Order granting the petition and declaring the marriage of the parties void from the beginning. The clerk of court issued a Certificate of Finality of the Order of the court on July 16, 1996.  Subsequently, on February 14, 1998, Valentine’s Day, Rodolfo Ancheta and his second wife Teresita H. Rodil were married in civil rights before the municipal mayor of Indang, Cavite.
 

However, on July 7, 2000, Rodolfo Ancheta's first wife - Marietta Ancheta, filed a Petition before the Court of Appeals questioning the annulment proceedings of the Regional Trial Court of Naic sometime in June 1995. Marietta Acheta wanted to nullify the decision of the annulment case on ground of lack of jurisdiction of Naic RTC over his person because according to her she was not notified of such case. She would have interposed an objection if she was only notified of such proceedings. The Court of Appeals dismissed her Petition. But the Supreme Court nullified the decision of the Court of Appeals on appeal. The Supreme Court expressed alarm at what transpired in the RTC of Naic, Cavite as shown by the records. The records show that the trial court granted the motion of Rodolfo to declare Marietta in default for her failure to file an Answer to Rodolfo's Petition for Annulment. The public prosecutor condoned the acts of the trial court when he interposed no objection to the motion of the respondent. The trial court forthwith received the evidence of the respondent ex-parte and rendered judgment against the petitioner without a whimper of protest from the public prosecutor. The actuations of the trial court and the public prosecutor are in defiance of the provisions of the Family Code.

 

January 29, 2004

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DAVID B. DEDEL versus COURT OF APPEALS and SHARON L. CORPUZ-DEDEL a.k.a. JANE IBRAHIM G.R. No. 151867.

 

Sexual Infidelity or Promiscuity does not constitute psychological incapacity. In this case, David B. Dedel filed a Petition to declare his marriage void on the ground of the psychological incapacity of his wife - Sharon. According to David, Sharon turned out to be an irresponsible and immature wife and mother. She had extra-marital affairs with several men: a dentist in the Armed Forces of the Philippines; a Lieutenant in the Presidential Security Command and later a Jordanian national. Sharon was once confirmed in the Manila Medical City for treatment by Dr. Lourdes Lapuz, a clinical psychiatrist. David also told that despite the treatment, Sharon did not stop her illicit relationship with the Jordanian national named Mustafa Ibrahim, whom she married and with whom she had two children. However, when Mustafa Ibrahim left the country, Sharon returned to him bringing along her two children by Ibrahim. He accepted her back and even considered the two illegitimate children as his own. But on December 9, 1995, Sharon abandoned David to join Ibrahim in Jordan with their two children. Since then, Sharon would only return to the country on special occasions. Finally, giving up all hope of a reconciliation with Sharon, David filed the Petition on April 1, 1997.

 

Dr. Natividad A. Dayan, who testified that Sharon was suffering from Anti-Social Personality Disorder exhibited by her blatant display of infidelity; that she committed several indiscretions and had no capacity for remorse, even bringing with her the two children of Mustafa Ibrahim to live with petitioner. Such immaturity and irresponsibility in handling the marriage like her repeated acts of infidelity and abandonment of her family are indications of Anti-Social Personality Disorder amounting to psychological incapacity to perform the essential obligations of marriage. The Regional Trial of Makati, the Court where the case was filed granted the Petition.

 

But According to the Supreme Court, Sharon's sexual infidelity or perversion and abandonment do not by themselves constitute psychological incapacity within the contemplation of the Family Code. Neither could her emotional immaturity and irresponsibility be equated with psychological incapacity. It must be shown that these acts are manifestations of a disordered personality which make respondent completely unable to discharge the essential obligations of the marital state, not merely due to her youth, immaturity or sexual promiscuity. The Decision of the RTC, Makati granting the Petition is reversed. Consequently, the Petition to declare the marriage void is dismissed.

 

Other Related Cases:

 

January 29, 2004

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VERONICO TENEBRO versus THE HONORABLE COURT OF APPEALS. [EN BANC] G.R. No. 150758.


An individual who contracts a second or subsequent marriage during the subsistence of a valid marriage is criminally liable for bigamy, notwithstanding the subsequent declaration that the second marriage is void on the ground of psychological incapacity.

 

 
 

 

 

 

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