Rowena and Edward were childhood neighbors in Dupax del Norte, Nueva Vizcaya. Sometime in 1987, they met again and became sweethearts but Edward’s family did not approve of their relationship. After graduation from college in 1991, Edward promised to marry Rowena as soon as he found a job. The job came in 1993, when the Philippine Air Lines (PAL) accepted Edward as a computer engineer. Edward proposed to Rowena that they first have a “secret marriage” in order not to antagonize his parents. Rowena agreed; they were married in Manila on February 23, 1993. Rowena and Edward, however, never lived together; Rowena stayed with her sister in Fairview, Quezon City, while Edward lived with his parents in Novaliches.
Rowena and respondent saw each other every day during the first six months of their marriage. At that point, Edward refused to live with Rowena for fear that public knowledge of their marriage would affect his application for a PAL scholarship. Seven months into their marriage, the couple’s daily meetings became occasional visits to Rowena’s house in Fairview; they would have sexual trysts in motels. Later that year, Edward enrolled at FEATI University after he lost his employment with PAL.
In 1994, the parties’ respective families discovered their secret marriage. Edward’s mother tried to convince him to go to the United States, but he refused. To appease his mother, he continued living separately from Rowena. Edward forgot to greet Rowena during her birthday in 1992 and likewise failed to send her greeting cards on special occasions. Edward indicated as well in his visa application that he was single.
In April 1995, Edward’s mother died. Edward blamed Rowena, associating his mother’s death to the pain that the discovery of his secret marriage brought. Pained by Edward’s action, Rowena severed her relationship with Edward. They eventually reconciled through the help of Rowena’s father, although they still lived separately.
In 1997, Edward informed Rowena that he had found a job in Davao. A year later, Rowena and her mother went to Edward’s house in Novaliches and found him cohabiting with one Cynthia Villanueva (Cynthia). When she confronted Edward about it, he denied having an affair with Cynthia. Rowena apparently did not believe Edwards and moved to to Nueva Vizcaya to recover from the pain and anguish that her discovery brought.
Rowena filed a Petition for Declaration of Nullity of Marriage against Edward. Aside from her oral testimony, the petitioner also presented a certified true copy of their marriage contract; and the testimony, curriculum vitae, and psychological report of clinical psychologist Dr. Nedy Lorenzo Tayag (Dr. Tayag).
Dr. Tayag declared on the witness stand that she administered the following tests on Rowena: a Revised Beta Examination; a Bender Visual Motor Gestalt Test; a Rorschach Psychodiagnostic Test; a Draw a Person Test; a Sach’s Sentence Completion Test; and MMPI. She thereafter prepared a psychological report with his findings. According to his evaluation, the character traits of Edward reveal him to suffer Narcissistic Personality Disorder – declared to be grave, severe and incurable. However, at the end of his findings, Dr. Tayag incorporated his personal idea about love. Love, according to him, means:
“Love happens to everyone. It is dubbed to be boundless as it goes beyond the expectations people tagged with it. In love, “age does matter.” People love in order to be secure that one will share his/her life with another and that he/she will not die alone. Individuals who are in love had the power to let love grow or let love die – it is a choice one had to face when love is not the love he/she expected.”
The Regional Trial Court nullified the marriage of Rowena and Edward.
The Republic, through the OSG, appealed the RTC decision to the CA. The CA reversed and set aside the RTC decision, and denied the nullification of the parties’ marriage.
In its ruling, the CA observed that Dr. Tayag’s psychiatric report did not mention the cause of the Edward’s so-called “narcissistic personality disorder;” it did not discuss the Edward’s childhood and thus failed to give the court an insight into the Edward’s developmental years. Dr. Tayag likewise failed to explain why she came to the conclusion that the Edward’s incapacity was “deep-seated” and “incurable.”
Rowena then went up to the Supreme Court. Among her prayer is the remanding of the case to the RTC for further reception of evidence. She argues that the inadequacy of her evidence during the trial was the fault of her former counsel, Atty. Richard Tabago, and asserts that remanding the case to the RTC would allow her to cure the evidentiary insufficiencies.
a) Whether a remand of the Case to the RTC is improper.
b) Whether Dr. Tayag’s Report is sufficient to justify the nullification of their marriage.
When the case reached the Supreme Court, it ruled that Rowena failed to establish the Edward’s psychological incapacity.
First, as to the remand of the case to the RTC, the Court said:
A remand of the case to the RTC for further proceedings amounts to the grant of a new trial that is not procedurally proper at this stage. Section 1 of Rule 37 provides that an aggrieved party may move the trial court to set aside a judgment or final order already rendered and to grant a new trial within the period for taking an appeal. In addition, a motion for new trial may be filed only on the grounds of (1) fraud, accident, mistake or excusable negligence that could not have been guarded against by ordinary prudence, and by reason of which the aggrieved party’s rights have probably been impaired; or (2) newly discovered evidence that, with reasonable diligence, the aggrieved party could not have discovered and produced at the trial, and that would probably alter the result if presented.
In the present case, the Rowena cites the inadequacy of the evidence presented by her former counsel as basis for a remand. She did not, however, specify the inadequacy. That the RTC granted the petition for declaration of nullity prima facie shows that the Rowena’s counsel had not been negligent in handling the case. Granting arguendo that the Rowena’s counsel had been negligent, the negligence that would justify a new trial must be excusable, i.e. one that ordinary diligence and prudence could not have guarded against.
As to the findings of Dr. Tayag, the Supreme Court notes that said findings was based mainly on her assessment of Rowena. The Court states:
We cannot help but note that Dr. Tayag’s conclusions about Edward’s psychological incapacity were based on the information fed to her by only one side – Rowena – whose bias in favor of her cause cannot be doubted. While this circumstance alone does not disqualify the psychologist for reasons of bias, her report, testimony and conclusions deserve the application of a more rigid and stringent set of standards in the manner we discussed above. For, effectively, Dr. Tayag only diagnosed Edward from the prism of a third party account; she did not actually hear, see and evaluate Edward and how he would have reacted and responded to the doctor’s probes.
The Court therefore ruled that:
“We find these observations and conclusions insufficiently in-depth and comprehensive to warrant the conclusion that a psychological incapacity existed that prevented Edward from complying with the essential obligations of marriage. It failed to identify the root cause of Edward’s narcissistic personality disorder and to prove that it existed at the inception of the marriage. Neither did it explain the incapacitating nature of the alleged disorder, nor show that Edward was really incapable of fulfilling his duties due to some incapacity of a psychological, not physical, nature.
source: Rowena Padilla-Rumbaua vs. Edward Rumbaua (G.R. No. 166738, August 14, 2009)