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Leni O. Choa vs. Alfonso C. Choa G.R. No. 143376

Leni Choa filed a motion to dismiss her husband Alfonso Choa's case for annulment of their marriage based on alleged psychological incapacity. The trial court denied the motion. On appeal, the Supreme Court ruled in favor of Leni Choa, finding that Alfonso Choa provided grossly insufficient evidence to support his claim of Leni Choa's psychological incapacity. Specifically, the evidence that Leni Choa filed various legal charges against Alfonso Choa did not demonstrate the required elements of gravity, juridical antecedence, and incurability needed to prove psychological incapacity.

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77 views1 page

Leni O. Choa vs. Alfonso C. Choa G.R. No. 143376

Leni Choa filed a motion to dismiss her husband Alfonso Choa's case for annulment of their marriage based on alleged psychological incapacity. The trial court denied the motion. On appeal, the Supreme Court ruled in favor of Leni Choa, finding that Alfonso Choa provided grossly insufficient evidence to support his claim of Leni Choa's psychological incapacity. Specifically, the evidence that Leni Choa filed various legal charges against Alfonso Choa did not demonstrate the required elements of gravity, juridical antecedence, and incurability needed to prove psychological incapacity.

Uploaded by

Edward Gamonnac Balocnit
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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LENI O. CHOA vs. ALFONSO C.

CHOA
G.R. No. 143376
November 26, 2002

FACTS:
Leni Choa, petitioner, and Alfonso Choa, respondent, were married on March 15, 1981. Out of
this union, two children were born. On October 27, 1993, respondent filed a complaint for the
annulment of his marriage to petitioner. Also filed an amended complaint for the declaration of
nullity of his marriage based on her alleged psychological incapacity. The case went on trial with
the respondent presenting his evidence. However, petitioner filed a motion to dismiss the
evidence. RTC denied petitioner‘s demurrer to evidence on the ground that petitioner must
controvert the established quantum evidence of respondent. Petitioner elevated the case to CA
after the motion of reconsideration was denied. CA held that denial of the demurrer was merely
interlocutory and petitioner in her defense must present evidence.

ISSUE:
Whether or not petitioner‘s obligated to present her evidence despite the inadequate evidence of
respondent in the annulment of marriage case grounded on psychological incapacity.

RULING:
The petition is meritorious. However, the evidence against petitioner is grossly insufficient to
support any finding of psychological incapacity that would warrant a declaration of nullity of the
parties‘ marriage.

Respondent claims that the filing by petitioner of a series of charges against him are proof of the
latter‘s psychological incapacity to comply with the essential obligations of marriage. These
charges included Complaints for perjury, false testimony, concubinage and deportation.
The documents presented by respondent during the trial do not in any way show the alleged
psychological incapacity of his wife. It is the height of absurdity and inequity to condemn her as
psychologically incapacitated to fulfill her marital obligations, simply because she filed cases
against him. The evidence presented merely establishes the prosecution of the cases against him.
To rule that the filings are sufficient to establish her psychological incapacity is not only totally
erroneous, but also grave abuse of discretion bordering on absurdity.
Court clearly explained that "psychological incapacity must be characterized by (a) gravity, (b)
juridical antecedence and (c) incurability. The evidence adduced by respondent merely shows
that he and his wife could not get along with each other. There was absolutely no showing of the
gravity or juridical antecedence or incurability of the problems besetting their marital union.

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