Republic v. Crasus L. Iyoy · G.R. 152577

Petitioner: Republic
Respondent: Crasus L. Iyoy
Citation: G.R. No. 152577
Court: Supreme Court
Division: Second Division
Ponente: Chico-Nazario, J.
Decided: September 21, 2005

Summary

The Supreme Court reversed lower court decisions that declared null and void the 1961 marriage between Crasus Iyoy and Fely Rosal-Iyoy. Crasus sought nullity based on his wife's alleged psychological incapacity after she abandoned the family in 1984, obtained divorce abroad, and remarried an American citizen. The RTC and Court of Appeals granted the petition, but the Supreme Court found insufficient evidence to establish the grave, incurable psychological incapacity required under Article 36 of the Family Code. The Court emphasized that abandonment, infidelity, and difficult behavior, while problematic, do not constitute the serious mental illness necessary for nullity. The Court also ruled that Article 26 of the Family Code was inapplicable since Fely was still Filipino when she divorced. The decision reinforced constitutional protection of marriage validity and the principle that doubts should favor marriage continuation over dissolution.

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Divorce in the Philippines

By the Intellegal Editorial Board · September 21, 2005

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