Noel Buenaventura v. Court of Appeals

Summary

This consolidated case involves Noel Buenaventura's petition for nullity of marriage against Isabel Singh Buenaventura based on psychological incapacity. The RTC declared the marriage void and awarded substantial damages and property division. The Supreme Court modified the decision, deleting all damage awards due to the inherent contradiction between psychological incapacity (lack of free will) and willful acts required for moral damages. The Court sustained property distribution but corrected the legal basis from conjugal partnership to co-ownership rules applicable to void marriages under Article 147 of the Family Code. The case establishes important precedent that psychological incapacity negates the possibility of willful acts necessary for damage awards, and clarifies that void marriages are governed by co-ownership rather than conjugal partnership property regimes.