Lanuza vs. Lanuza

Unjustified absence from the marital home for decades, coupled with other manifestations such as infidelity and contracting subsequent marriages, can be considered as part of the totality of evidence proving that a person is psychologically incapacitated to comply with the essential obligations of marriage under Article 36 of the Family Code.

Leonora O. Dela Cruz-Lanuza and Alfredo M. Lanuza, Jr. were married in June 1984 and had four children. According to Leonora, their married life started smoothly but later deteriorated when Alfredo began coming home late, neglecting his family, and engaging in illicit affairs. The couple eventually separated in 1994. Following their separation, Alfredo abandoned the family completely, failed to provide any financial support, and reportedly entered into two subsequent marriages with other women, which became the basis for Leonora's petition to have their marriage declared void.

• Leonora O. Dela Cruz-Lanuza and Alfredo M. Lanuza, Jr. were married on June 9, 1984, and had four children.
• Leonora claimed that after a smooth start, Alfredo began neglecting his family, staying out late, engaging in illicit affairs, and failing to provide financial support.
• The couple separated in 1994, after which Alfredo completely abandoned his family, visiting his children only once in 1999 for less than an hour.
• Leonora presented a certification from the Philippine Statistics Authority showing three marriage records under Alfredo's name: to her in 1984, to Mary Ann Makalintal in 1994, and to Jane Alejo in 2000.
• Alfredo, a former police officer, was dismissed from service after going AWOL due to a bigamy case filed against him by Leonora.
• Leonora presented clinical psychologist Noel N. Ison as an expert witness, who diagnosed Alfredo with Narcissistic Personality Disorder with underlying Borderline Personality Traits.
• Ison's evaluation was based on interviews with Leonora, her sister, and her daughter, as Alfredo did not respond to the invitation to be assessed.
• The Regional Trial Court denied the petition, finding the evidence of subsequent marriages insufficient and doubting the psychologist's report because it lacked specific details and was not based on a personal examination of Alfredo.
• The Court of Appeals dismissed Leonora's appeal on purely procedural grounds, ruling she had availed of the wrong remedy (a Petition for Review under Rule 42 instead of an ordinary appeal under Rule 41).

• The Court of Appeals committed grave abuse of discretion by dismissing her petition on a mere technicality instead of ruling on its merits.
• The Regional Trial Court erred in finding that Alfredo's two subsequent marriages and total abandonment of his family were insufficient to prove his psychological incapacity.
• The totality of Alfredo's actions clearly demonstrates his inability to comprehend and fulfill the essential duties and obligations of marriage.
• The psychological evaluation, even without a direct examination of Alfredo, is valid and sufficient as it is based on collateral information from persons who knew him well, which is an accepted practice in psychiatry.

• The Court of Appeals correctly dismissed the appeal on procedural grounds because the petitioner availed of the wrong legal remedy.
• The evidence presented by the petitioner is insufficient to prove psychological incapacity, as Alfredo's actions at most show a mere refusal or difficulty in performing his marital obligations, not a debilitating psychological condition.
• The psychologist's findings are unreliable as he was unable to personally examine Alfredo and relied on information from biased sources (the petitioner and her relatives).
• The petitioner failed to prove that Alfredo's alleged personality disorder was grave, incurable, and had juridical antecedence.
• Private respondent Alfredo M. Lanuza, Jr. never filed any responsive pleading despite multiple notices from the Supreme Court.

• Procedural Issues:
  • Whether the Court of Appeals erred in dismissing the Petition for Review on the ground that it was the wrong remedy.
• Substantive Issues:
  • Whether the totality of evidence presented is sufficient to declare the marriage void on the ground of respondent Alfredo M. Lanuza, Jr.'s psychological incapacity.

• Procedural:
  • The Supreme Court held that the Court of Appeals did not err in dismissing the appeal, as the proper remedy from an RTC decision in the exercise of its original jurisdiction is an ordinary appeal under Rule 41, not a Petition for Review under Rule 42. However, the Court opted to relax the procedural rules and give due course to the petition because a review of the substantive matters showed that the case was meritorious.
• Substantive:
  • The Supreme Court granted the petition and declared the marriage void. It ruled that the pieces of evidence presented sufficiently established Alfredo's psychological incapacity. His infidelity, complete abandonment of his family for decades, failure to provide any support, and contracting multiple subsequent marriages demonstrated a total lack of understanding of his essential obligations as a husband and father. The Court affirmed the validity of the psychological evaluation based on collateral information, reiterating the doctrine in Tan-Andal v. Andal that a personal examination of the incapacitated spouse is not indispensable. The psychologist's testimony adequately explained that Alfredo's Narcissistic Personality Disorder was grave, had juridical antecedence (stemming from his upbringing), and was incurable due to his lack of insight into his condition.

• Psychological Incapacity (Article 36, Family Code) — The Court, citing Tan-Andal, reiterated that psychological incapacity is a legal, not a medical, concept. It refers to a durable aspect of a person's personality structure that makes it impossible for them to comply with their essential marital obligations. In this case, Alfredo's actions were not seen as mere refusal but as clear manifestations of a dysfunctional personality structure that rendered him incapable of fulfilling his duties.
• Totality of Evidence Rule — This principle requires courts to consider all evidence presented to determine if psychological incapacity has been proven by clear and convincing evidence. The Supreme Court applied this by collectively viewing Alfredo's decades-long absence, financial abandonment, and multiple marriages not as isolated acts of infidelity or irresponsibility, but as a cohesive pattern demonstrating his psychological incapacity.
• Psychological Evaluation Based on Collateral Information — The Court affirmed that a personal examination of the respondent is not a mandatory requirement for a psychological evaluation to be admissible. An expert may base their findings on collateral information from individuals who have knowledge of the respondent's life and behavior. This was applied to validate the psychologist's diagnosis of Alfredo, which was based on interviews with his wife, sister-in-law, and daughter.
• Relaxation of Procedural Rules — The Court invoked its discretion to suspend procedural rules in the interest of substantial justice, especially when the case is meritorious. It applied this doctrine to excuse the petitioner's procedural error in filing the wrong mode of appeal with the Court of Appeals, allowing the case to be decided on its substantive merits.

• "Unjustified absence from the marital home for decades may be considered as part of the totality of evidence that a person is psychologically incapacitated to comply with the essential obligations of marriage."

• Tan-Andal v. Andal — Cited as the landmark and controlling precedent that clarified psychological incapacity as a legal concept, not a medical illness, and established that expert testimony is not mandatory and that proof must be clear and convincing.
• Georfo v. Republic — Referenced to reiterate the Tan-Andal ruling that a personal psychiatric examination of the alleged incapacitated spouse is not indispensable and that an evaluation may be based on collateral information.
• Malixi v. Baltazar — Cited as the basis for relaxing procedural rules, enumerating instances where suspension of the rules is justified, such as when the merits of the case are strong.
• Perez-Ferraris v. Ferraris — This case was cited by the Office of the Solicitor General to argue that the respondent's actions were a mere refusal to comply with marital obligations. The Supreme Court's decision implicitly distinguished the facts of the present case by finding a deeper, clinically identified personality disorder.

• Family Code, Article 36 — This is the central provision defining psychological incapacity as a ground for declaring a marriage void.
• Family Code, Article 68 — Cited to enumerate the essential marital obligations, including the duty to live together, observe mutual love, respect, and fidelity, and render mutual help and support, which the respondent failed to fulfill.
• Family Code, Article 220 — Cited to outline the duties of parents towards their children, which the respondent also failed to perform.
• Rules of Court (1997), Rule 41 — Identified as the proper mode of appeal (ordinary appeal) that the petitioner should have filed from the RTC's decision rendered in its original jurisdiction.
• Rules of Court (1997), Rule 42 — Identified as the incorrect remedy availed by the petitioner, as this rule applies to appeals from RTC decisions rendered in their appellate jurisdiction.