Scribd
Upload
132 views2 pages

Calma v. Santos-Calma, G.R. No. 242070 CASE DIGEST

Jeffrey filed a petition to nullify his marriage to Kris due to psychological incapacity. The trial court dismissed the petition, but the Supreme Court reversed. The Supreme Court found sufficient evidence that Kris suffered from schizoid personality disorder and was psychologically incapacitated from fulfilling her marital obligations based on testimony from Jeffrey, his mother, and a psychologist. The marriage between Jeffrey and Kris was declared null and void due to Kris' psychological incapacity.

Uploaded by

Kenshin De Los Trinos
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
132 views2 pages

Calma v. Santos-Calma, G.R. No. 242070 CASE DIGEST

Jeffrey filed a petition to nullify his marriage to Kris due to psychological incapacity. The trial court dismissed the petition, but the Supreme Court reversed. The Supreme Court found sufficient evidence that Kris suffered from schizoid personality disorder and was psychologically incapacitated from fulfilling her marital obligations based on testimony from Jeffrey, his mother, and a psychologist. The marriage between Jeffrey and Kris was declared null and void due to Kris' psychological incapacity.

Uploaded by

Kenshin De Los Trinos
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Calma v. Santos-Calma, G.R. No.

242070
Doctrine: Declaring a marriage to be null and void due to psychological incapacity is
valid whence evidence from petitioner suffices to prove without unreasonable doubt that
respondent was unable to fulfill their marital duties due to their diagnosis.

Facts: Jeffrey M. Calma (Jeffrey) and Mari Kris Santos-Calma (Kris) were wedded in
civil rites on the 15th of August 2005. Immediately after which Jeffrey received news that
his visa for a three-year contract as an overseas Filipino worker in the middle east was
granted. Due to this, both parties came into a mutual agreement that Kris would reside
with Jeffrey’s family in Pampanga seeing as she was not in good terms with her
parents.

On the 31st of December 2005, Kris gave birth to their son which was aptly named Josh
Xian. Kris has proceeded to reside in different cities, namely: Bulacan and Quezon City,
a few months after giving birth while citing misunderstanding with relatives as her
justification.

Throughout this ordeal, Kris’ monetary demands began to increase with her claiming
that the funds would be used for Josh Xian. She, also, frequently changed her number
in 2008 which roused suspicion in Jeffrey’s mind along with Kris asking for money while
claiming that she needed it because she was in “deep trouble.” With Jeffrey’s contact
soon to expire, he had asked Kris to wait for him to get back to the Philippines to
procure the funds that she needed.

Once back, Jeffrey did not get the chance to meet nor contact Kris directly. He had to
travel to Bulacan to claim Josh Xian and was informed by his in-laws that it would be
best to start anew seeing as his wife was already pregnant and cohabitating with
another man.

In 2013, Jeffrey considered having his marriage declared null and void and had enlisted
the help of Dr. Leo Ruben C. Manrique to interview the parties involved along with their
relatives. During which Dr. Manrique was able to conclude that Kris suffered from
Schizoid personality disorder, manifested maladaptive behavioral patterns, and was
psychologically incapacitated to the extent of which she was deemed incapable of
fulfilling her essential marital obligations.

The appellant then filed a petition to have his marriage with the appellee nullified on the
grounds of psychological incapacity whilst presenting himself, his mother, and Dr.
Manrique as key witnesses.

The RTC dismissed Jeffrey’s petition on account of his supposed failure to show the
gravity, juridical antecedence, and incurability of Kris' psychological capacity. A decision
which was later affirmed by the CA while also citing supposed inadequacies with Dr.
Manrique’s findings.
Issue: Whether or not the parties’ marriage is null and void due to psychological
incapacity

Ruling: Yes. The court held that the petition to declare the marriage null and void on
the ground of psychological incapacity pursuant to Article 36 of the Family code is valid
therefore ruling in favor of the petitioner.
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.

You might also like