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Case Digest - G.R. No. 159220 - Dimayuga-Laurena vs. Court of Appeals

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Shainna Turqueza
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33 views3 pages

Case Digest - G.R. No. 159220 - Dimayuga-Laurena vs. Court of Appeals

Uploaded by

Shainna Turqueza
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Title

Dimayuga-Laurena vs. Court of Appeals

Case Decision Date


G.R. No. 159220 Sep 22, 2008

A woman !les for the nullity of her marriage, claiming her husband's
psychological incapacity, but fails to provide su"cient evidence, leading to
the denial of her petition by the Supreme Court.

Case Digest (G.R. No. 159220)


Comprehensive

Facts:

Ma. Darlene Dimayuga-Laurena (petitioner) and Jesse Lauro Laurena


(respondent) were married on December 19, 1983.

They have two children: Mark Jordan (born 1985) and Michael Joseph (born
1987).

On October 19, 1993, Darlene !led for the declaration of nullity of her marriage,
claiming Jesse was psychologically incapacitated.

Darlene alleged that Jesse's incapacity existed at the time of their marriage,
although she became aware of it later.

Incidents cited by Darlene included:

A honeymoon trip to Baguio City with a minor.

A miscarriage shortly after becoming pregnant.

Jesse's prioritization of his parents' needs.

Frequent late-night absences and in!delity.

Darlene characterized Jesse's behavior as irresponsible and insensitive,


suggesting a bachelor's lifestyle.

Jesse denied the allegations, claiming Darlene was emotionally immature and
unreasonable.

The Regional Trial Court of Makati City denied Darlene's petition on March 25,
:
1997, citing insu"cient evidence of psychological incapacity.

Darlene appealed, and the Court of Appeals a"rmed the trial court's ruling on
June 6, 2003, while modifying aspects related to properties acquired during the
marriage.

Darlene subsequently sought a review from the Supreme Court.

Issue:

Is Jesse Lauro Laurena psychologically incapacitated to comply with the


essential obligations of marriage?

Do the properties excluded by the Court of Appeals form part of the conjugal
partnership of gains between Darlene and Jesse?

Ruling:

The Supreme Court ruled that the petition had no merit.

It a"rmed the Court of Appeals' decision to deny the annulment of marriage and
the dissolution of the conjugal partnership of gains.

The Court modi!ed the ruling to include the duplex house and lot on Dayap
Street, Makati City, in the conjugal partnership of gains.

Ratio:

The petition for declaration of nullity was based on Article 36 of the Family
Code, which requires psychological incapacity to be grave, judicially antecedent,
and incurable.

The burden of proof rests with the petitioner, and doubts about the marriage's
validity should favor its maintenance.

Darlene failed to provide su"cient evidence of Jesse's psychological incapacity


at the time of marriage.

Testimony from Dr. Lourdes Lapuz, the psychiatrist, was deemed vague and
ambiguous, lacking a clear identi!cation of Jesse's alleged incapacity.

While a medical examination is not strictly necessary, the incapacity must be


medically identi!ed and substantiated.

Allegations of irresponsibility, in!delity, and abandonment do not constitute


valid grounds for declaring a marriage void.
:
The Court upheld the exclusion of certain properties belonging to Jesse's
parents from the conjugal partnership but included the duplex house on Dayap
Street, as it was acquired during the marriage and lacked evidence to support
Jesse's claim of exclusion.
:

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