Saturday, April 12, 2014

Azcueta v. Republic, G.R. No. 180668, May 26, 2009

FACTS: Petitioner Marietta C. Azcueta and Rodolfo Azcueta met in 1993 and got married on July  of the same year. They separated in 1997 after four years of marriage. They had no children. Marietta filed a petition for declaration of absolute nullity of her marriage before the RTC. Marietta averred that Rodolfo was psychologically incapacitated to comply with the essential obligations of marriage. Petitioner complained that Rodolfo never bothered to look for a job and instead always asked his mother for financial assistance. When they were married it was Rodolfo’s mother who found them a room near the Azcueta home and it was also his mother who paid the monthly rental. Petitioner also testified that she constantly encouraged her husband to find employment and even bought new shoes and clothes to inspire him. Sometime later, her husband told petitioner that he already found a job and petitioner was overjoyed. However, some weeks after, petitioner was informed that her husband had been seen at the house of his parents when he was supposed to be at work. Petitioner discovered that her husband didn’t actually get a job and the money he gave her (which was supposedly his salary) came from his mother. When she confronted him about the matter, Rodolfo allegedly cried like a child and told her that he pretended to have a job so that petitioner would stop nagging him about applying for a job. Petitioner complained that every time Rodolfo would get drunk he became physically violent towards her. Their sexual relationship was also unsatisfactory. They only had sex once a month and petitioner never enjoyed it. When they discussed this problem, Rodolfo would always say that sex was sacred and it should not be enjoyed nor abused. He did not even want to have a child yet because he claimed he was not ready. Additionally, when petitioner requested that they move to another place and rent a small room rather than live near his parents, Rodolfo did not agree. Because of this, she was forced to leave their residence and see if he will follow her. But he did not. Dr. Cecilia Villegas testified that Rodolfo is suffering from Dependent Personality Disorder characterized by loss of self-confidence, constant self-doubt, inability to make his own decisions and dependency on other people. She added that the root cause of this psychological problem was a cross-identification with the mother who was the dominant figure in the family considering that respondent’s father was a seaman and always out of the house. She stated that this problem began during the early stages in his life but manifested only after the celebration of his marriage. According to Dr. Villegas, this kind of problem was also severe because he will not be able to make and to carry on the responsibilities expected of a married person. It was incurable because it started in early development and therefore deeply ingrained into his personality. RTC declared marriage void ab initio. CA reversed RTC’s decision.

ISSUE: W/N Rodolfo is psychologically incapacitated


HELD: Rodolfo’s psychological incapacity was also established to have clearly existed at the time of and even before the celebration of marriage. Witnesses were united in testifying that from the start of the marriage, Rodolfo’s irresponsibility, overdependence on his mother and abnormal sexual reticence were already evident. These manifestations of Rodolfo’s Dependent Personality Disorder must have existed even prior to the marriage being rooted in his early development and a by-product of his upbringing and family life.

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