G.R. No. 249178 . July 13, 2022.
AIDA EGMALIS-KE-EG, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Aida Egmalis-Ke-eg filed a petition to declare her marriage to Ireneo Ke-eg null and void under Article 36 of the Family Code, citing his psychological incapacity. The couple, belonging to the Kankana-ey Tribe, married in January 1983 after Aida became pregnant, primarily due to community pressure. Aida testified that Ireneo was habitually unemployed, preferred drinking with friends, and failed to provide support for her and their son. Their cohabitation was brief and marked by conflict, leading Aida to work abroad. They eventually ceased communication, and Aida had not seen Ireneo since 1988. A psychologist, based on interviews with Aida and other informants, diagnosed Ireneo with Antisocial Personality Disorder, concluding it was grave, incurable, and existed prior to the marriage.
The Regional Trial Court (RTC) granted the petition, declaring the marriage null and void due to the psychological incapacity of both parties, accepting the psychologist’s findings. The Republic, through the Office of the Solicitor General (OSG), appealed. The Court of Appeals (CA) reversed the RTC, finding the evidence insufficient to prove Ireneo’s psychological incapacity met the required standards of juridical antecedence, gravity, and incurability. The CA characterized Ireneo’s behavior as mere irresponsibility and immaturity. Aida elevated the case to the Supreme Court via a Petition for Review.

ISSUE

Whether the Court of Appeals erred in reversing the RTC Decision and in ruling that the evidence was insufficient to prove Ireneo’s psychological incapacity to comply with his essential marital obligations.

RULING

The Supreme Court granted the petition, reversed the CA Decision, and reinstated the RTC’s declaration of nullity. The Court applied the guidelines set forth in Tan-Andal v. Andal, which abandoned the rigid Molina doctrine and adopted a more holistic, case-to-case assessment of psychological incapacity. The Court emphasized that the incapacity must be shown to be an enduring trait that seriously compromises the parties’ ability to fulfill the basic marital obligations of cohabitation, mutual support, and love and respect.
The Court found that the totality of evidence, including Aida’s unrebutted testimony and the psychologist’s findings, clearly established Ireneo’s psychological incapacity. His persistent refusal to work, habitual drunkenness, abandonment of his family, and failure to provide material and emotional support from the inception of the marriage and continuing for decades demonstrated a grave and incurable incapacity to assume his marital duties. His antisocial behavior, as clinically identified, was deeply rooted and manifested before the marriage. The Court held that his actions constituted more than mere difficulty, neglect, or ill will; they reflected a true inability to understand and perform the fundamental obligations of marriage. Consequently, the marriage was declared void ab initio under Article 36.