Facts:
Leonora and Alfredo were married in 1984. At first their marriage was fine, but later on Alfredo’s behavior changed. He would come home late from nights out with friends. He neglected his duty and did not provide food for the family. He also engaged in illicit affairs. They finally separated in 1994; later on she learned that Alfredo married Mary Ann in 1994; and in 2000, he married another woman, Jane.
Leonora thus filed a petition for declaration of nullity of her marriage to Alfredo, on the grounds of lack of marriage license, and psychological incapacity under Article 36.
Both the RTC and the CA denied Leonora’s petition.
On appeal to the Supreme Court, the Court brushed aside the procedural infirmity of Leonora’s improper appeal to the CA, and decided the petition on the merits, by granting her petition.
Ruling:
“We find that the pieces of evidence presented by petitioner sufficiently establish the psychological incapacity of the respondent.
Based on the facts, respondent left his family in 1994 and appears to have contracted marriage several times, with different women. He never gave financial support to his children and only visited them once, for less that an hour. These indicate that respondent did not understand his obligations as a husband and father.”
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“From the foregoing, it is clear that Ison was able to explain how respondent’s personality disorder developed from his childhood and how it is correlated to his inability to fulfill his obligations as a husband and father.
To restate, the gravity of respondent’s personality disorder is shown by his lack of recognition that he has responsibilities to his wife and children.
His personality disorder appears to have been fostered by how he was raised by his family as “he was deprived of appropriate parental supervision and guidance” and :his parents’ lenient and tolerable attitude encouraged him to become extremely assertive. This shows that there is juridical antecedence. His psychological incapacity developed during his formative years and existed prior to this marriage to petitioner.
The incurability of respondent’s personality disorder was also explained by Ison when he stated in his Judicial Affidavit that those who are diagnosed with narcissistic personality disorder “strongly deny that they are mentally ill, reject the idea of seeking professional help and therefore refuse any form of psychiatric treatment.”
Respondent’s infidelity, failure to give support to his wife and children, and unjustified absence from his family are all indicative that he is not cognizant of the duties and responsibilities of a husband and father.” (Citations omitted)
LEONORA O. DELA CRUZ-LANUZA, petitioner, vs. ALFEDO M. LANUZA, JR and the REPUBLIC OF THE PHILIPPINES, respondents. G.R. No. 242362, April 17, 2024
Leonen, J.