G.R. No. 147824. August 2, 2007.
ROSA YAP PARAS, petitioner, vs. JUSTO J. PARAS, respondent.

FACTS

Petitioner Rosa Yap Paras filed a complaint for annulment of her marriage to respondent Justo J. Paras under Article 36 of the Family Code, alleging his psychological incapacity. Rosa claimed that Justo failed to fulfill his marital obligations from the beginning of their marriage in 1964. She presented evidence that he did not provide financial support, forcing her to rely on her own business income, and that he lived a bachelor-like lifestyle, spending time with friends instead of his family. She further testified to his profligacy, including dissipating business assets and forging her signature in a mortgage. The final catalyst was his cohabitation with another woman and siring an illegitimate child.
Justo denied the allegations, attributing financial losses to a sugar price slump and claiming Rosa became cold and detached after a trip to the United States. He argued his return from the U.S. was due to visa limitations from his mayoral duties and denied the mistress allegation. The Regional Trial Court dismissed the petition, finding Rosa’s evidence insufficient to prove psychological incapacity. The Court of Appeals affirmed, holding that the facts established mere neglect, not the grave, antecedent, and incurable condition required by law.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the petition for annulment by failing to find that the respondent is psychologically incapacitated to comply with his essential marital obligations.

RULING

The Supreme Court granted the petition, reversed the appellate decision, and declared the marriage null and void. The Court clarified that the guidelines in Molina do not mandate an examination by a physician; what is crucial is the presence of evidence adequately establishing a party’s psychological condition. The Court found that the totality of evidence presented by Rosa, including testimonies from their children, sufficiently proved Justo’s psychological incapacity.
The legal logic is that psychological incapacity must be shown to be grave, rooted in the party’s history antedating the marriage, and incurable. The evidence demonstrated that Justo’s irresponsibility, profligacy, and infidelity were not mere post-marital neglect but manifestations of a profound inability to understand and perform the basic obligations of marriage, which existed at the time of the wedding. His consistent pattern of failing to provide support, abandoning his family, and engaging in extramarital affairs constituted a refusal or inability to assume the essential responsibilities of a married life, meeting the required standards of gravity, juridical antecedence, and incurability under Article 36.