Rambaua vs. Rambaua

89. Rowena Padilla-Rumbaua vs. Edward Rumbaua Dr.
Tayag likewise failed to explain why she came to the

(G.R. No. 166738, August 14, 2009) conclusion that the Edward’s incapacity was “deep-seated”
and “incurable.”
FACTS:
Thus, the instant case.
Rowena and Edward were sweethearts but Edward’s
family did not approve of their relationship.
They had “secret marriage” in order not to antagonize ISSUES:

Edward’s parents.
Whether Dr. Tayag’s Report is sufficient to justify the
They, however, never lived together; Rowena stayed with nullification of their marriage.
her sister in Fairview, Quezon City, while Edward lived
with his parents in Novaliches.
RULING: NO.
Sometime in the year 1998, Rowena found Edward
cohabiting with one Cynthia Villanueva (Cynthia) in his When the case reached the Supreme Court, it ruled that
house in Novaliches. Rowena failed to establish the Edward’s psychological
incapacity.
He denied having an affair with Cynthia.
As to the findings of Dr. Tayag, the Supreme Court notes
Rowena filed a Petition for Declaration of Nullity of
that said findings was based mainly on her assessment of
Marriage against Edward.
Rowena.
Aside from her oral testimony, the petitioner also
The Court states:
presented a certified true copy of their marriage contract;
and the testimony, curriculum vitae, and psychological We cannot help but note that Dr. Tayag’s conclusions about
report of clinical psychologist Dr. Nedy Lorenzo Tayag (Dr. Edward’s psychological incapacity were based on the
Tayag). information fed to her by only one side – Rowena – whose
bias in favor of her cause cannot be doubted.
Dr. Tayag declared on the witness stand that she
administered the following tests on Rowena: a Revised While this circumstance alone does not disqualify the
Beta Examination; a Bender Visual Motor Gestalt Test; a psychologist for reasons of bias, her report, testimony and
Rorschach Psychodiagnostic Test; a Draw a Person Test; a conclusions deserve the application of a more rigid and
Sach’s Sentence Completion Test; and MMPI. stringent set of standards in the manner we discussed
above.
She thereafter prepared a psychological report with his
findings. According to his evaluation, the character traits of For, effectively, Dr. Tayag only diagnosed Edward from the
Edward reveal him to suffer Narcissistic Personality prism of a third party account; she did not actually hear,
Disorder – declared to be grave, severe and incurable. see and evaluate Edward and how he would have reacted
and responded to the doctor’s probes.
However, at the end of his findings, Dr. Tayag
incorporated his personal idea about love. Love, according The Court therefore ruled that:
to him, means:
“We find these observations and conclusions insufficiently
“Love happens to everyone. in-depth and comprehensive to warrant the conclusion
that a psychological incapacity existed that prevented
It is dubbed to be boundless as it goes beyond the
Edward from complying with the essential obligations of
expectations people tagged with it. In love, “age does
marriage.
matter.”
It failed to identify the root cause of Edward’s narcissistic
People love in order to be secure that one will share
personality disorder and to prove that it existed at the
his/her life with another and that he/she will not die
inception of the marriage.
alone.
Neither did it explain the incapacitating nature of the
Individuals who are in love had the power to let love grow
alleged disorder, nor show that Edward was really
or let love die – it is a choice one had to face when love is
incapable of fulfilling his duties due to some incapacity of a
not the love he/she expected.”
psychological, not physical, nature.
The Regional Trial Court nullified the marriage of Rowena
and Edward.
The Republic, through the OSG, appealed the RTC decision

to the CA.
The CA reversed and set aside the RTC decision, and

denied the nullification of the parties’ marriage.
In its ruling, the CA observed that Dr. Tayag’s psychiatric

report did not mention the cause of the Edward’s so-called
“narcissistic personality disorder;” it did not discuss the
Edward’s childhood and thus failed to give the court an
insight into the Edward’s developmental years.

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89. Rowena Padilla-Rumbaua vs. Edward Rumbaua Dr.

Tayag likewise failed to explain why she came to the

They had “secret marriage” in order not to antagonize ISSUES:

The Republic, through the OSG, appealed the RTC decision

The CA reversed and set aside the RTC decision, and

In its ruling, the CA observed that Dr. Tayag’s psychiatric

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