Dean Manuel Ramon I.

Cabrera
Persons and Family Relations
MARIA TERESA B. TANI-DE LA FUENTE, vs.
RODOLFO DE LA FUENTE, JR.

GR No. 188400, March 8, 2017 

FACTS:

Petitioner Maria Teresa and respondent Rodolfo De La Fuente, Jr. when

they were still sweethearts, Maria Teresa already noticed that Rodolfo was an
introvert and was prone to jealousy. Rodolfo's attitude worsened as they went on
with their marital life. Sometime in 1986, after Rodolfo poked a gun at Maria
Teresa's head, together with her two (2) daughters, left their conjugal home. On
June 3, 1999, Maria Teresa filed a petition for declaration of nullity of marriage
on the ground of psychological incapacity before the RTC of Quezon City. As
support to her petitions, clinical psychologist, Dr. Arnulfo V. Lopez was
presented as an expert witness. However, Rodolfo did not file any responsive
pleading. The trial court eventually deemed his non-appearance as a waiver of
his right to present evidence.
On August 14, 2002, the trial court promulgated its decision granting the
petition for declaration of nullity of marriage. The Court of Appeals reversed the
decision of the RTC. In its resolution dated May 25, 2009, CA denied the motion
for reconsideration filed by Maria Teresa.
ISSUE:

WON the CA erred when it denied the Declaration of the Nullity of

marriage.
RULING:

Yes, the Court of Appeals erred in denying the petition for Declaration of
Nullity of Marriage. Petitioner was able to discharge the burden of proof that
respondent suffered from psychological incapacity.
Article 68 of the Family Code obligates the husband and wife "to live
together, observe mutual love, respect and fidelity, and render mutual help and
support." In this case, petitioner and respondent may have lived together, but the
facts narrated by petitioner show that respondent failed to, or could not, comply
with the obligations expected of him as a husband. He was even apathetic that
petitioner filed a petition for declaration of nullity of their marriage. The
incurability and severity of respondent's psychological incapacity were likewise
discussed by Dr. Lopez. Respondent's repeated behavior of psychological abuse
by intimidating, stalking, and isolating his wife from her family and friends, as
well as his increasing acts of physical violence, are proof of his depravity, and
utter lack of comprehension of what marriage and partnership entail. After she
had exerted efforts to save their marriage and their family, respondent simply
refused to believe that there was anything wrong in their marriage. This shows
that respondent truly could not comprehend and perform his marital obligations.
This fact is persuasive enough for this Court to believe that respondent's mental
illness is incurable.
Thus, the marriage of Maria Teresa Tani-De La Fuente and Rodolfo De
La Fuente is declared NULL and VOID.

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CASE DIGEST OF: “Ad Astra Per Aspera” NCC Article: 36, 68
LOPECILLO, MERICHRIS A. JD-1A FAMILY CODE