JEFFREY M. CALMA, PETITIONER, VS.

MARI KRIS SANTOS-CALMA, RESPONDENT

FACTS:

Jeffrey and Mari had become sexually intimate after a month of meeting each other. Soon after, Mari
became pregnant and they decided to have marriage.

10 days after their marriage, Jeffrey went to middle east to work. They agreed that Mari would live with
Jeffrey’s parents.

Respondent gave birth to the child and decided to live with her parents. After a couple of months, Mari told
Jeffrey that she needed to leave Bulacan due to a misunderstanding with her father. Jeffrey then made
arrangements for Kris to live at his sister's house in Quezon City.

Jeffrey noticed that her wife demands for money escalated. In 2008, Mari changed her phone numbers in
rapid succession.

Upon Jeffrey’s return, her wife didn’t talk to him. Her parents even informed him that Mari was already
cohabiting with another man.

This led to Jeffrey considering the possibility of having his marriage null. Jeffrey engaged Dr. Manrique’s
services

After interviews with Jeffrey, Kris, and their relatives. Dr. Manrique concluded that Kris:
(1) was suffering from schizoid personality disorder;
(2) manifested maladaptive behavioral patterns; and
(3) was psychologically incapacitated to such an extent that she was "incapable of performing essential
marital obligations.

Subsequently, Jeffrey filed a Petition for Declaration of Nullity of Marriage on account of psychological
incapacity but RTC denied his petition. RTC claimed that Dr. Manrique’s findings are not sufficient. Jeffrey
raised the petition to the CA but CA sustained the RTC’s decision.

ISSUE:

Whether or not the gravity, juridical antecedence, and incurability of Kris' psychological capacity has been
shown as would justify the declaration of nullity of her marriage to Jeffrey.

RULING:

In keeping with contemporary standards on appraising Article 36 cases, this Court finds that the Court of
Appeals and Regional Trial Court erred in failing to appreciate that respondent's condition was attended by
gravity, juridical antecedence, and incurability, thereby warranting a declaration that her marriage to
petitioner is void.

Witnesses recounted several damaging occurrences and circumstances. None of these were ever
successfully rebutted.

Respondent showed herself utterly incapable of "living together, observing mutual love, respect and fidelity,
and rendering mutual help and support" with her husband.

Mari Kris Santos-Calma has brought great strain to the marriage and had exposed her husband and son to
severe mental and emotional torture.

WHEREFORE, the Petition is GRANTED. The June 21, 2018 Decision and August 22, 2018 Resolution of
the Court of Appeals in CA-G.R. CV No. 109155 are REVERSED and SET ASIDE. The marriage of Jeffrey
M. Calma with respondent Mari Kris Santos-Calma is declared NULL and VOID.

SO ORDERED.
CLAUDINE MONETTE BALDOVINO-TORRES, PETITIONER, VS. JASPER A. TORRES, RESPONDENT

FACTS:

Claudine and Jasper met in the year 2000 through text messaging. After a few months, they
got romantically involved until Claudine became pregnant with their child.

Despite the initial objection from Claudine's mother, the couple got married on July 10, 2002.

Claudine decided to go back to school after the birth of their son. Jasper had jobs but he
eventually quit after short period of time.

Jasper continued to live a carefree life. His drinking habits worsened: when drunk, he would
force Claudine to have sex that the latter felt like being raped. He had likewise become
increasingly aggressive towards Claudine.

Eventually, Claudine decided to leave him. She left their son with Jasper's parents to work in
Manila. Later on, she went to Singapore. Her efforts to reconcile with Jasper proved to be
futile as she later learned that Jasper had a child with another woman.

The antecedents prompted Claudine to file a Petition for Declaration of Nullity of Marriage
under Article 36 of the Family Code12 against Jasper before the RTC.

In addition to Claudine's testimony in court, the following also testified: Nora Ng Baldovino
(Nora), Claudine's mother; and Clinical Psychologist Nedy Tayag.

Nora described Jasper as irresponsible, both as a husband and father, as he depended too
much on his parents.

On the other hand, Dr. Tayag maintained that Jasper's psychological incapacity is grave,
serious, chronic, severe, and incurable by any form of treatment. She recommended that the
marriage between Jasper and Claudine be declared null and void as it was doomed from the
start.

On January 30, 2017, the RTC rendered a Decision20 declaring the marriage of Jasper and
Claudine as null and void.

The Office of the Solicitor General (OSG), representing the Republic of the Philippines, filed
a Motion for Reconsideration. On appeal, the CA reversed the ruling of the RTC. Claudine
moved for a reconsideration of the assailed Decision, but the CA denied it for lack of merit in
its subsequent Resolution.

ISSUES:

1. whether the CA erred in not giving credence to the expert testimony of the clinical
psychologist;
2. whether the CA erred in ruling that the totality of evidence does not show that the
disorder of Jasper is that which is contemplated by Article 36 of the Family Code; and
3. whether the CA erred when it did not dismiss the appeal outright as the RTC Decision
had already become final and executory

RULING:

The Court grants the petition.