Republic v. Crasus-Iyoy

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REPUBLIC OF THE PHILIPPINES, petitioner vs CRASUS L.

IYOY respondent
G.R. No. 101749. July 10, 1992
Topic: Lex Loci Celebrationis on Marriage
Facts:
Respondent Crasus married Fely at a church in Cebu City on December 1961. They had
five children – Crasus Jr., Daphne, Debbie, Calvert, Carlos (of legal age at the time of the
filing of the case). Later on, respondent Crasus discovered Fely was “hot-tempered,
nagger, and extravagant”.
In 1984, Fely left the Philippines for the United States leaving all of their five children to
the care of respondent Crasus. Barely a year after Fely left, respondent Crasus received
a letter from her requesting his signature on the enclosed divorce papers, but Crasus
disregarded the request.
Through the letters Fely sent to her children, Crasus learned that Fely got married to an
American citizen and had a child.
Respondent Crasus filed a complaint against Fely of danger and dishonor to the family,
and clearly demonstrated psychological incapacity which being incurable constituted a
ground for declaration of nullity of marriage. Fely answered that she was already married
to Stephen Micklus; had admitted her previous marriage with Crasus but accused the
latter to be a drunkard, womanizer, and insincere in effort to find employment. Being the
sole breadwinner, she decided to work in the US so that she could continue to provide
financial support to her family.
Fely argued that her marriage with American husband was legal because she had already
obtained an American citizen so her status is governed by the law of her present
nationality.
She demanded that Crasus must pay back the 90,000 she sent for their son Calvert’s
brain operation which misused by Crasus, with interest and moral and exemplary
damages, among others.
Regional Trial Court: Marriage of the respondent Crasus and Fely was void ab initio on
the basis of psychological incapacity because Fely abandoned her family, filed a divorce
decree in the US and married another man.
Petitioner Republic filed a Motion for Reconsideration declaring the RTC’s ruling as
contrary to law and evidence pursuant to Art. 26 of the Family Code. Court of Appeals
denied the petition.
Issue: Whether or not Fely was psychologically incapacitated as grounds for the
declaration of the nullity of marriage
Ruling: The Supreme Court ruled that Fely was not psychologically incapacitated
because totality of evidence presented by respondent Crasus was an insufficient proof.
The characteristics, behavior, acts of Fely do not satisfactorily establish psychological or
mental defect. Fely’s abandonment, sexual infidelity, bigamy are grounds to file for legal
separation (under Article 55 of the Family Code). The petition was granted. The marriage
of Crasus Iyoy and Fely Iyoy remains valid and subsisting.

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