The Supreme Court denied Matudan's petition for annulment of his marriage. The Court affirmed the lower courts' rulings that Matudan failed to sufficiently prove his wife, Marilyn, was psychologically incapacitated at the time of their marriage. Specifically, the Court found Matudan's evidence based on third-party accounts of Marilyn's behavior were inadmissible hearsay. Additionally, the Court ruled mere neglect of marital duties does not constitute psychological incapacity. As the appellate courts affirmed the trial court's factual findings, the Supreme Court declined to reweigh evidence or resolve other issues raised in the petition.
Original Description:
Original Title
Rodriguez, Ritz A._Nicolas Matudan v. Republic , et al., G.R. No. 203284 Nov. 14, 2016
The Supreme Court denied Matudan's petition for annulment of his marriage. The Court affirmed the lower courts' rulings that Matudan failed to sufficiently prove his wife, Marilyn, was psychologically incapacitated at the time of their marriage. Specifically, the Court found Matudan's evidence based on third-party accounts of Marilyn's behavior were inadmissible hearsay. Additionally, the Court ruled mere neglect of marital duties does not constitute psychological incapacity. As the appellate courts affirmed the trial court's factual findings, the Supreme Court declined to reweigh evidence or resolve other issues raised in the petition.
The Supreme Court denied Matudan's petition for annulment of his marriage. The Court affirmed the lower courts' rulings that Matudan failed to sufficiently prove his wife, Marilyn, was psychologically incapacitated at the time of their marriage. Specifically, the Court found Matudan's evidence based on third-party accounts of Marilyn's behavior were inadmissible hearsay. Additionally, the Court ruled mere neglect of marital duties does not constitute psychological incapacity. As the appellate courts affirmed the trial court's factual findings, the Supreme Court declined to reweigh evidence or resolve other issues raised in the petition.
Art. 36 of the Family Code states: A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization.
Article 68 of the same Code provides:
'The husband and wife are obliged to live together, observe mutual love, respect and fidelity, and render mutual help and support.'
MATUDAN v. REPUBLIC, 2016
Facts: >> Matudan filed a petition for review on certiorari on the decision and resolution of the CA denying the petition of the CA and motion for reconsideration ; thus, affirming the decision of the RTC of Quezon City Branch 94 which dismissed the petition for annulment of marriage. >> Private respondent Marilyn, after cohabitating with the petitioner Matudan for six (6) years left for abroad to work, however, she has never been heard and whereabouts were not disclosed to her family. She was not able to give love, care and support to her husband and kids. >> It has been determined that the petitioner’s evidence to sufficiently prove that Marilyn was psychologically unfit for marriage failed, and dismissal is deemed appropriate ruling of both the trial and appellate courts. Petitioner could not establish its gravity, juridical antecedence, and incurability. Issue: >> Whether or not psychological incapacity exists in the given case calling for annulment. Ruling: >> Making hasty generalization based from a third-party narrative, is no different from admitting hearsay evidence as proof of truthfulness of content of such evidence, thus, any information on Marilyn’s psychological incapacity, based from the testimony of the petitioner can not be used as proof. >> Mere neglect or inability to function and give the proper care, love and support from a mother to her children as well to her husband, is not a manifestation of psychological incapacity. >> In the instant case, however, is beyond the jurisdiction of this Court to review. The task to analyze or weigh all over again the evidence or premises supportive of such factual determination is not of the Courts responsibility. It is of standard that factual findings of the trial court, when affirmed by the Court of Appeals, are binding on this Court, thus, there is no need to resolve the other issues raised. >> Thus, the petition is DENIED and the CA’s decision are AFFIRMED.