Republic of the Philippines vs. Ramoran-Wong

A marriage is void ab initio under Article 36 of the Family Code when the psychological incapacity of a spouse is established by clear and convincing evidence of juridical antecedence, gravity, and incurability, as interpreted under the Tan-Andal framework, and no collusion exists between the parties to fabricate grounds or suppress evidence. Expert testimony is not indispensable; ordinary witnesses who observed the incapacitated spouse's behavior before and during the marriage may suffice, and incurability is understood in the legal, not medical, sense.

Ma. Theresa Ramoran-Wong and Vincent L. Wong met in 2010 at a birthday party and were married on March 8, 2012, after Theresa became pregnant and their parents convinced Vincent to marry. The Republic, through the Office of the Solicitor General, participates in the proceedings as counsel for the State pursuant to Article 48 of the Family Code and A.M. No. 02-11-10-SC, which mandate State intervention in nullity proceedings to guard against collusion and fabrication or suppression of evidence.

Sometime in 2010, Ma. Theresa Ramoran-Wong and Vincent L. Wong met at a birthday party of a common friend's child. Vincent obtained Theresa's cellphone number and began courting her via text the following day. After four months of personal visits, they became a couple. Within a month of dating, Theresa observed that Vincent lacked direction and ambition, spending most of his time with peers and indulging in various vices. Despite having practical skills in electricity, he resisted seeking employment, claiming work would interfere with his social life. He began requesting money from Theresa to support his habits and was highly jealous and possessive, forbidding her from interacting with anyone, stalking her, and threatening to harm anyone who interfered with their relationship. Theresa attempted to break up with Vincent, but he threatened suicide, and fearing for her well-being, she reluctantly stayed.

Theresa eventually came to love Vincent and became pregnant. Upon learning of the pregnancy, Vincent reacted angrily and insisted on abortion. Theresa opposed the idea and sought the support of their parents, who convinced Vincent to marry her. They were married on March 8, 2012. Three weeks after the wedding, Vincent disappeared for three days. When he returned, he told Theresa not to worry if he was with his friends, as they were more important than her, and claimed she had forced him into marriage and that she alone wanted the child. Vincent's behavior persisted throughout the marriage: he frequently went on drinking binges, left Theresa without financial support or knowledge of his whereabouts, and responded violently to criticism, even throwing kitchenware during one argument. His addictions to cockfighting, alcohol, and gambling further strained the relationship.

Three months into the marriage, Theresa discovered that Vincent had rekindled a relationship with his ex-girlfriend. When confronted, Vincent admitted the affair, claiming the ex-girlfriend provided joy that Theresa could not. This led to their separation, but with parental intervention, they reconciled, and Vincent promised to change. His behavior instead worsened: he became increasingly erratic, violent, and emotionally detached. Whenever Theresa sought comfort during her pregnancy, he avoided her, dismissing her emotional needs as overdramatic. He insulted her publicly, even in front of family members, and would come home late and intoxicated, forcing Theresa into violent and bizarre forms of sexual intercourse. When she resisted due to her pregnancy, he threatened her with a balisong and claimed he would rekindle his relationship with his ex-girlfriend. To avoid controversy, Theresa would relent, but each time she was overwhelmed with pain, plagued by feelings of low self-esteem and demoralization.

After the birth of their son, Gian Angelo Wong, Vincent became more apathetic and indifferent, remaining insensitive to his family's needs. When Theresa urged him to find work, he responded with anger. Theresa took on sole responsibility for supporting the family by securing a teaching job but was forced to quit after Vincent publicly slapped her for refusing to give him money for his vices. Aware of Gian's needs, Theresa went to Hong Kong in 2013 to work as a domestic helper, leaving Gian in her mother's care. During this time, Vincent neither visited Gian nor provided support. Theresa eventually learned that Vincent was cohabiting with another woman and had fathered an illegitimate child. After Theresa returned to the Philippines, they attempted to reconcile for Gian's sake, but their relationship deteriorated further as Vincent continued to subject Theresa to physical, psychological, and economic abuse.

Theresa filed a Petition for the Declaration of Nullity of their marriage on the basis of psychological incapacity under Article 36 of the Family Code. On May 10, 2016, the RTC issued a summons directing Vincent to file his Answer. When Vincent failed to do so, the RTC ordered the Provincial Prosecutor to investigate whether collusion existed. Associate Provincial Prosecutor Sherwin Eria Domingo reported that no collusion existed between the parties. Trial on the merits ensued. Theresa testified on her own behalf and presented the testimonies and Judicial Affidavits of her mother Agnes P. Ramoran, Vincent's father Vicente T. Wong, Vincent's cousin Shella Wong Albano, and clinical psychologist Dr. Gemma Marie Alhama, who conducted psychological assessments on both parties. Neither Vincent nor the State offered evidence in opposition. The RTC dismissed the petition, finding the witnesses' testimonies incredible and exaggerated, and holding that the alleged behavior fell short of the threshold for psychological incapacity. The CA reversed, giving due weight to Dr. Alhama's report and the witness testimonies, and declared the marriage void ab initio.

• Collusion: The Republic argued that Theresa and Vincent colluded to have their marriage declared null and void, pointing to Vincent's allowance of his father Vicente to testify "for this problem to be solved" and Vicente's admission that Vincent was willing to have his marriage annulled and was not opposing the petition.
• Insufficiency of Evidence: The Republic contended that because the evidence presented by Theresa was the result of collusion and fabrication with Vincent, such evidence lacked probative value and could not overcome the strong presumption in favor of the validity of marriage. The Republic maintained that Theresa did not prove, by clear and convincing evidence, that Vincent suffers from psychological incapacity to perform his marital obligations.
• Jurisdictional Grounds: The Republic asserted that the CA's findings were contrary to those of the trial court and based on a misapprehension of facts, bringing the case within recognized exceptions to the rule that factual issues are not cognizable under a Rule 45 petition.

• Collusion: Whether collusion existed between Theresa and Vincent, thereby warranting the dismissal of the Petition for the Declaration of Nullity of Marriage.
• Psychological Incapacity: Whether the CA committed reversible error in ruling that Theresa had established, through clear and convincing evidence, the requisites of incurability, gravity, and juridical antecedence, necessary for a finding of psychological incapacity.

• Collusion: No. The parties' mutual desire to void their marriage does not equate to collusion; a lack of objection is not the same as collusion absent evidence of fabricated offenses or suppressed defenses, and the public prosecutor's investigation report finding no collusion is entitled to the presumption of regularity.
• Psychological Incapacity: No reversible error. The CA correctly found that Theresa established juridical antecedence, gravity, and incurability through clear and convincing evidence, including ordinary witness testimony and Dr. Alhama's psychological evaluation, under the Tan-Andal framework.

• Collusion: Collusion, as defined in De Ocampo vs. Florenciano, refers to an agreement between husband and wife for one to commit or appear to commit a matrimonial offense, or to suppress evidence of a valid defense, to enable the other to obtain a divorce. The Republic's argument rested on Vincent's consent to his father and cousin testifying for Theresa and his willingness to have the marriage annulled. The Court emphasized that mutual desire for dissolution does not necessarily equate to collusion, and a lack of objection is not the same as collusion. In the absence of evidence that the parties conspired to fabricate a matrimonial offense or colluded to obtain nullity without valid grounds, a finding of collusion is unwarranted. The severity of the spouses' marital conflicts is reason enough to encourage relatives from both sides to testify. Vincent's failure to file an answer and present evidence does not automatically prove collusion, as held in Puyat vs. Puyat and Juliano-Llave vs. Republic of the Philippines. Moreover, APP Domingo issued an Investigation Report affirming the absence of collusion, which is entitled to the presumption of regularity.

• Psychological Incapacity: Article 36 of the Family Code declares void a marriage contracted by a party who, at the time of celebration, was psychologically incapacitated to comply with essential marital obligations. The Court applied the modified Tan-Andal guidelines, which abandoned the second Molina guideline requiring the root cause to be medically or clinically identified, and redefined incurability in the legal rather than medical sense. Under Tan-Andal, psychological incapacity is neither a mental incapacity nor a personality disorder that must be proven through expert opinion; rather, proof of a durable "personality structure" that manifests through clear acts of dysfunctionality undermining the family suffices, and ordinary witnesses may testify to behaviors consistently observed from the incapacitated spouse. Juridical antecedence was established through testimonies of Vincent's father and cousin regarding his long-standing behavioral issues evident before he met Theresa, corroborated by Dr. Alhama's finding that the onset of his personality disorders dated back to early childhood, attributed to the dysfunctional relationship between his parents. Theresa's testimony about her experiences with Vincent both as girlfriend and wife demonstrated that his incapacity was already present at the time of marriage. Gravity was proven through Dr. Alhama's diagnosis of Narcissistic, Antisocial, and Histrionic Personality Disorders, and through Vincent's complete failure to comprehend and fulfill his responsibilities as husband and father — his refusal to seek employment, failure to provide moral and financial support, demands for money to fund vices, and persistent physical, psychological, and economic abuse. Incurability was demonstrated by an undeniable pattern of persisting failure to be a present, loving, faithful, respectful, and supportive spouse, with maladaptive behaviors deeply ingrained as permanent aspects of his personality pervading all areas of his life.

• Psychological Incapacity under Article 36 (Tan-Andal framework) — Psychological incapacity is fundamentally characterized by gravity, juridical antecedence, and incurability. It is neither a mental incapacity nor a personality disorder that must be proven through expert opinion. Proof of a durable "personality structure" that manifests through clear acts of dysfunctionality undermining the family suffices. Ordinary witnesses present in the life of the spouses before marriage may testify to behaviors consistently observed. Juridical antecedence requires showing the incapacity exists at the time of celebration, even if it manifests only during the marriage; it may be proven by testimonies describing the environment where the incapacitated spouse lived. Incurability is understood in the legal, not medical, sense: the incapacity must be so enduring and persistent with respect to a specific partner that the only result would be the inevitable and irreparable breakdown of the marriage, demonstrated by an undeniable pattern of persisting failure to be a present, loving, faithful, respectful, and supportive spouse. Gravity requires that the incapacity be caused by a genuinely psychic cause, excluding mild characteriological peculiarities, mood changes, occasional emotional outbursts, or mere refusal, neglect, difficulty, or ill will.

• Collusion in Nullity Proceedings — Collusion refers to a secret agreement or cooperation between husband and wife for one to commit or appear to commit a matrimonial offense, or to suppress evidence of a valid defense, to enable the other to obtain a declaration of nullity. The parties' mutual desire to void their marriage does not necessarily equate to collusion; a lack of objection is not the same as collusion. In the absence of evidence that the parties conspired to fabricate a matrimonial offense or colluded to obtain nullity without valid grounds, a finding of collusion is unwarranted. A spouse's failure to file an answer or present evidence does not automatically prove collusion. The State's participation through the public prosecutor and the Solicitor General is mandated under Article 48 of the Family Code and A.M. No. 02-11-10-SC to guard against collusion.

• Presumption of Validity of Marriage — The burden of proof to show nullity belongs to the plaintiff, and any doubt is resolved in favor of the existence and continuation of marriage. The quantum of proof required is clear and convincing evidence — more than preponderant evidence but less than proof beyond reasonable doubt.

• Substantial Compliance with Verification — A defective verification does not ipso facto render a pleading fatally defective. The Court may proceed to act on the pleading where substantial compliance is evident — when the verification is executed by a party with sufficient knowledge to attest to the truth of the allegations, and when such allegations are made in good faith and are true and correct.

• "The parties' mutual desire to void their marriage does not necessarily equate to collusion. A lack of objection is not the same as collusion. In the absence of any evidence that the parties conspired to fabricate a matrimonial offense or colluded to obtain a declaration of nullity without valid grounds, a finding of collusion is unwarranted." — This passage articulates the controlling distinction between mutual consent to dissolve a marriage and actionable collusion, a critical principle in nullity proceedings where State participation is mandated to prevent collusive dissolutions.

• "[P]sychological incapacity is neither a mental incapacity nor a personality disorder that must be proven through expert opinion. There must be proof, however, of the durable or enduring aspects of a person's personality, called 'personality structure,' which manifests itself through clear acts of dysfunctionality that undermines the family." — This is the canonical formulation from Tan-Andal vs. Andal as quoted and applied in the decision, representing the decisive departure from the rigid Molina requirement of medical or clinical identification of the root cause.

• "[A]n undeniable pattern of such persisting failure [to be a present, loving, faithful, respectful, and supportive spouse] must be established so as to demonstrate that there is indeed a psychological anomaly or incongruity in the spouse relative to the other." — This passage defines the standard for legal incurability under the Tan-Andal framework, shifting the inquiry from medical treatability to the enduring incompatibility of the spouses' personality structures.

• "Marriage, in its truest form, must be a sanctuary: a space of mutual respect, care, and emotional safety. It must never become a chain that binds a person to a relationship that is not only fundamentally flawed, but damaging." — This passage from the Conclusion reflects the Court's normative vision of marriage as both an inviolable institution and one whose continuation must not become oppressive when irreparably broken by psychological incapacity.

• Republic vs. Court of Appeals and Molina, 335 Phil. 664 (1997) — The seminal case laying down the original eight guidelines for interpreting and applying Article 36 of the Family Code. The Court in this decision applied the Tan-Andal modifications, specifically abandoning the second Molina guideline requiring medical or clinical identification of the root cause and amending the third guideline on incurability.

• Tan-Andal vs. Andal, 902 Phil. 558 (2021) — The controlling precedent that modified the Molina guidelines, redefining psychological incapacity as a legal (not medical) concept, abandoning the requirement of expert opinion, and restating the three characteristics of juridical antecedence, gravity, and incurability. This decision applied the Tan-Andal framework directly to affirm the CA's ruling.

• Georfo vs. Republic, 937 Phil. 518 (2023) — Summarized the Tan-Andal guidelines into three key points: the quantum of proof (clear and convincing evidence), the abandonment of the medical identification requirement in favor of "personality structure" proof, and the restatement of the three characteristics of psychological incapacity. The Court relied on this summary in applying the Tan-Andal framework.

• Puyat vs. Puyat, 906 Phil. 143 (2021) — Cited for the proposition that a spouse's failure to testify or present evidence should not be automatically equated with collusion, and that a petition may be validly resolved without the non-appearing spouse's testimony when other evidence supports the ruling.

• Juliano-Llave vs. Republic of the Philippines, 662 Phil. 203 (2011) — Cited alongside Puyat for the principle that a respondent spouse's failure to file an answer and present evidence does not automatically prove collusion and should not benefit the non-participating party.

• De Ocampo vs. Florenciano, 107 Phil. 35 (1960) — Cited for the definition of collusion in the context of matrimonial proceedings, providing the foundational formulation that the Court applied in rejecting the Republic's collusion argument.

• Quitalig vs. Quitalig, 909 Phil. 506 (2021) — Cited for the principle that a defective verification does not ipso facto render a pleading fatally defective, and that substantial compliance may suffice in the interest of substantial justice.

• Article 36, Family Code — Declares void a marriage contracted by any party who, at the time of celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, even if such incapacity becomes manifest only after its solemnization. The provision was the substantive basis for declaring the marriage between Theresa and Vincent void ab initio.

• Article 48, Family Code — Mandates that in all cases of annulment or declaration of absolute nullity of marriage, the court shall order the prosecuting attorney or fiscal to appear on behalf of the State to prevent collusion and ensure evidence is not fabricated or suppressed, and that no judgment shall be based upon a stipulation of facts or confession of judgment. This provision undergirded the Republic's participation and the investigation for collusion.

• A.M. No. 02-11-10-SC (Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages) — Sections 8, 9, 13, and 15 were cited to reinforce State participation in nullity proceedings, including the public prosecutor's duty to investigate collusion, report findings, and appear for the State at pre-trial and trial to prevent fabrication or suppression of evidence.

• Rule 7, Section 4, Rules of Court — Sets forth the required attestations for verification of pleadings: that allegations are true and correct based on personal knowledge or authentic documents, that the pleading is not filed to harass or cause delay, and that factual allegations have evidentiary support. The Court found substantial compliance despite the verification's omission of two attestations.

• Article 1, Family Code — Referenced in the Conclusion for the principle that marriage is the foundation of the family and an inviolable social institution that the State is duty-bound to protect.

Caguioa (Chairperson), Inting, Gaerlan, and Dimaampao, JJ., concurred. No separate concurring opinions were noted.