G.R. No. 180668; May 26, 2009
MARIETA C. AZCUETA, Petitioner, vs. REPUBLIC OF THE PHILIPPINES AND THE COURT OF APPEALS, Respondents.

FACTS

Petitioner Marieta Azcueta filed a petition to declare her marriage to Rodolfo Azcueta null and void under Article 36 of the Family Code, alleging his psychological incapacity. She testified that Rodolfo was emotionally immature, irresponsible, and financially dependent on his mother, refusing to seek employment. He deceived her about having a job, exhibited physical violence when drunk, and maintained an unsatisfactory sexual relationship, stating sex was sacred and not to be enjoyed. They separated in 1997 after four years of marriage. Petitioner presented her psychiatrist, Dr. Cecilia Villegas, who diagnosed Rodolfo with Dependent Personality Disorder, characterized by severe inadequacy, an inability to make decisions, and dependency rooted in early cross-identification with his dominant mother. Dr. Villegas concluded the condition was grave, incurable, and rendered him incapable of marital obligations.
The Regional Trial Court granted the petition, declaring the marriage null and void. The Republic, through the Office of the Solicitor General, appealed. The Court of Appeals reversed the RTC decision, finding the evidence insufficient to prove psychological incapacity. It held that the behaviors described—irresponsibility, refusal to work, and dependency—did not constitute the psychological incapacity contemplated by Article 36, as they were not shown to be rooted in a psychological illness existing at the time of the marriage. The CA emphasized the lack of personal examination of Rodolfo by the expert witness.

ISSUE

Whether the Court of Appeals erred in reversing the RTC decision and in holding that the evidence was insufficient to prove Rodolfo Azcueta’s psychological incapacity to comply with the essential marital obligations.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic rests on the stringent requirements for nullity under Article 36, as established in Republic v. Molina and reiterated in Tan-Andal v. Andal. Psychological incapacity must be a grave, juridical antecedent condition that is medically or clinically identified, incurable, and completely incapacitates a person from fulfilling marital obligations. Mere difficulty, refusal, or neglect in performing these duties, or personality traits like irresponsibility and immaturity, are insufficient without proof of a psychological illness.
Here, the evidence failed to meet this standard. The psychiatrist’s evaluation of Rodolfo was based solely on information provided by the petitioner, not on a personal clinical examination. The behaviors cited—financial dependency, deceit about employment, and marital strife—were not conclusively proven to be manifestations of a psychological disorder existing at the inception of the marriage. The Court held that these acts, while indicative of marital failure, do not equate to the psychological incapacity required by law. The State’s policy to protect marriage as an inviolable social institution demands clear and convincing evidence of a grave psychological illness, which was not satisfactorily established in this case.