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Photo credits: MEME 

Case: ROWENA  PADILLA-RUMBAUA vs.TEDWARD RUMBAUA (G.R. No. 166738, August 14, 2009)

The love story of Rowena and Edward

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.

When love is gone

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.

When you married a mama’s boy 

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.

When you married a mama’s boy and a babaero 

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.

The Nullity Case

Rowena filed a Petition for Declaration of Nullity of Marriage against Edward. Rowena presented, among others, the 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 Supreme Court’s Ruling 

When the case reached the Supreme Court, it ruled that Rowena failed to establish the Edward’s psychological incapacity.

The Supreme Court notes that his (Dr. Tayag) 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.

While the Court denied the Petition of Rowena, meaning, her marriage to Edward still subsists, it ruled further:

 “The Court commiserates with Rowena’s marital predicament. Edward may indeed be unwilling to discharge his marital obligations, particularly the obligation to live with one’s spouse. Nonetheless, we cannot presume psychological defect from the mere fact that respondent refuses to comply with his marital duties.xxx, it is not enough to prove that a spouse failed to meet his responsibility and duty as a married person; it is essential that he must be shown to be incapable of doing so due to some psychological illness. The psychological illness that must afflict a party at the inception of the marriage should be a malady so grave and permanent as to deprive the party of his or her awareness of the duties and responsibilities of the matrimonial bond he or she was then about to assume.