Saturday, April 12, 2014

Te v.Te, G.R. No. 161793, Feb. 13, 2009

FACTS: Edward Te first got a glimpse of respondent Rowena Ong Gutierrez Yu-Te in a gathering organized by the Filipino-Chinese association in their college. Edward was then initially attracted to Rowena’s close friend; but, as the latter already had a boyfriend, the young man decided to court Rowena. That was in January 1996, when petitioner was a sophomore student and respondent, a freshman. In March 1996, or around three months after their first meeting, Rowena asked Edward that they elope. At first, he refused, bickering that he was young and jobless. Her persistence, however, made him relent. Thus, they left Manila and sailed to Cebu that month; he, providing their travel money and she, purchasing the boat ticket. However, Edward’s P80,000.00 lasted for only a month. In April 1996, they decided to go back to Manila. Rowena proceeded to her uncle’s house and Edward to his parents’ home. As his family was abroad, and Rowena kept on telephoning him, threatening him that she would commit suicide, Edward agreed to stay with Rowena at her uncle’s place. On April 23, 1996, Rowena’s uncle brought the two to a court to get married. He was then 25 years old, and she, 20. The two then continued to stay at her uncle’s place where Edward was treated like a prisoner—he was not allowed to go out unaccompanied. Her uncle also showed Edward his guns and warned the latter not to leave Rowena. After a month, Edward escaped from the house of Rowena’s uncle, and stayed with his parents. His family then hid him from Rowena and her family whenever they telephoned to ask for him. In June 1996, Edward was able to talk to Rowena. Unmoved by his persistence that they should live with his parents, she said that it was better for them to live separate lives. They then parted ways.  On January 18, 2000, Edward filed a petition before the RTC for the annulment of his marriage to Rowena on the basis of her psychological incapacity.

ISSUE: Whether the marriage contracted is void on the ground of psychological incapacity.


HELD: The parties’ whirlwind relationship lasted more or less six months. They met in January 1996, eloped in March, exchanged marital vows in May, and parted ways in June. The psychologist who provided expert testimony found both parties psychologically incapacitated. Petitioner’s behavioral pattern falls under the classification of dependent personality disorder (to make everyday decisions without advice from others, and allows others to make most of his important decisions), and respondent’s, that of the narcissistic and antisocial personality disorder (her disregard in the rights of others, her abuse, mistreatment and control of others without remorse, and her tendency to blame others, impulsive and domineering; she had no qualms in manipulating petitioner with her threats of blackmail and of committing suicide). There is no requirement that the person to be declared psychologically incapacitated be personally examined by a physician, if the totality of evidence presented is enough to sustain a finding of psychological incapacity.

No comments:

Post a Comment