Green vs. Green

Psychological assessments based on the testimonies of the petitioner, respondent, respondent's mother, and a mutual friend can be given credence in proving psychological incapacity, especially when there is no reason to believe the testimonies are fabricated. The declaration of nullity of marriage is warranted as long as the totality of the evidence clearly and convincingly establishes one spouse's psychological incapacity to perform essential marital obligations.

In 2006, Jeffery A. Green, a United States Navy retiree, met Rowena Manlutac in a bar in Angeles City. They developed a relationship, during which Jeffery was aware Rowena had two children from a previous relationship and Rowena knew Jeffery's divorce was still pending. In 2008, Rowena gave birth to a daughter, Abigail, whom Jeffery acknowledged as his own. They married on May 8, 2010. Following the marriage, Jeffery discovered Rowena's infidelity, pathological gambling, deceitfulness regarding finances and the paternity of Abigail, and accumulation of significant debt, which led him to file a petition to have their marriage declared void.

• Jeffery Green, a US Navy retiree, and Rowena Manlutac met in 2006 and married on May 8, 2010.
• Before their marriage, Rowena gave birth to a child, Abigail, whom Jeffery acknowledged, but a subsequent DNA test revealed he was not the biological father.
• After marrying, the couple did not establish a fixed family domicile; Jeffery worked in Makati while Rowena divided her time between him and her other children in Angeles City.
• On July 7, 2014, Jeffery filed a petition for nullity of marriage based on psychological incapacity, submitting documentary evidence of Rowena's infidelity, lies, gambling, and debts amounting to around PHP 4 million.
• A key piece of evidence was a Psychiatric Evaluation Report by Dr. Ma. Bernadette Manalo-Arcena, which was based on interviews with Jeffery, Rowena, Rowena's mother, and a mutual friend.
• The report concluded that Rowena suffered from Borderline Personality Disorder and Antisocial Personality Disorder, which were rooted in her childhood and rendered her incapable of fulfilling her marital duties.
• Rowena was served summons but failed to file an answer to the petition or a pre-trial brief.

• The Court of Appeals erred in giving undue weight to the testimony and report of the psychologist, Dr. Manalo-Arcena.
• The psychologist did not have enough reliable and credible information to conclude that she had a psychological disorder.
• The petitioner's debts should not be considered a valid cause for declaring psychological incapacity.
• There was no evidence to prove her alleged infidelity, and the respondent already knew he was not the father of Abigail when he acknowledged her.
• Maintaining two separate households was her way of shielding her husband from her other children's problems and demonstrated her awareness of her obligations.
• The respondent failed to present sufficient evidence to justify the nullity of their marriage, which should be preserved by the Court.

• Jeffery Green argued that the finding of Rowena's psychological incapacity was based on vital factual evidence and not solely on the psychologist's report.
• Jeffery Green asserted that he successfully overcame the burden of proof by presenting clear and convincing evidence of Rowena's incapacity.
• The Republic of the Philippines, through the Office of the Solicitor General, contended that the totality of the evidence sufficiently proved Rowena's psychological incapacity, which was characterized by gravity, juridical antecedence, and incurability.

• Procedural Issues:
  • Whether the Supreme Court should review the factual findings of the lower courts, which is an exception to the general rule that a petition for review on certiorari should only raise questions of law.
• Substantive Issues:
  • Whether Rowena Manlutac Green is psychologically incapacitated to comply with the essential marital obligations under Article 36 of the Family Code, warranting the declaration of nullity of her marriage to Jeffery A. Green.

• Procedural:
  • The Supreme Court proceeded to evaluate the evidence presented, thereby exercising its discretion to review the factual findings, but ultimately found no reason to overturn the consistent conclusions of the Regional Trial Court and the Court of Appeals as they were fully supported by the evidence on record.
• Substantive:
  • The Supreme Court denied the petition and affirmed the lower courts' decisions, ruling that Jeffery Green had established Rowena's psychological incapacity with clear and convincing evidence. The Court found that Rowena's diagnosed Borderline and Antisocial Personality Disorders constituted a durable personality structure that was grave, legally incurable, and had juridical antecedence. This incapacity manifested through her deceit, infidelity, financial irresponsibility, and inability to commit to the essential marital obligations of living together, observing mutual love, respect, and fidelity, thereby rendering the marriage void ab initio.

• Psychological Incapacity (Article 36, Family Code) — This legal concept refers to a party's true and serious inability to comprehend and assume the essential obligations of marriage. The Court applied it by determining that Rowena's personality structure, characterized by Borderline and Antisocial Personality Disorders, made it impossible for her to comply with her marital duties, and this condition was grave, pre-existing, and legally incurable.
• Totality of Evidence Rule in Psychological Incapacity Cases — This principle requires that all evidence presented—including expert opinion, documentary evidence, and testimonies of ordinary witnesses—be considered as a whole to determine if psychological incapacity is proven. In this case, the Court found that the psychiatric report, which was based on interviews with multiple knowledgeable individuals and corroborated by documentary proof like collection cases and a DNA test result, collectively established Rowena's incapacity by clear and convincing evidence.
• Tan-Andal v. Andal Guidelines — This landmark doctrine liberalized the strict requirements of the previous Molina doctrine by clarifying that psychological incapacity is a legal, not a medical, concept. The Court applied this framework by emphasizing that a medical diagnosis is not essential, expert testimony is not mandatory (but may be considered), and incurability is to be understood in a legal sense (i.e., enduring and persistent relative to the specific partner). This allowed the Court to give weight to the psychiatric findings on Rowena's personality structure and dysfunctional behaviors without being constrained by a rigid clinical definition.

• "Psychological assessments based on testimonies of petitioner, respondent, respondent's mother, and the spouses' mutual friend may be given credence, unless there are reasons to believe that the testimonies are fabricated. As long as the totality of the evidence establishes petitioner's psychological incapacity, the declaration of nullity of marriage is warranted."

• Tan-Andal v. Andal — Cited as the controlling precedent that modified the strict Molina guidelines and established the current, more liberal framework for interpreting psychological incapacity under Article 36, which the Court directly applied in this case.
• Georfo v. Republic — Referenced to reaffirm the Tan-Andal guidelines and to support the principle that a psychological assessment can be given credence even if based on sources other than the petitioner, such as family members or friends, thereby strengthening the evidentiary value of the report against Rowena.
• Republic v. Court of Appeals and Molina — Mentioned to provide historical context on the evolution of the doctrine of psychological incapacity, as its rigid guidelines were the standard before being modified by Tan-Andal.
• Datu v. Datu — Cited as a recent application of the Tan-Andal doctrine, illustrating that an enduring psychosis forming part of a person's personality structure can be a valid basis for psychological incapacity, which is analogous to Rowena's diagnosed personality disorders.

• Article 36 of the Family Code — This is the statutory basis of the entire case, as it provides for the nullity of a marriage where one party, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations.