GR 159594; (November, 2012) (Digest)
G.R. No. 159594 ; November 12, 2012
Republic of the Philippines, Petitioner, vs. The Hon. Court of Appeals (Ninth Division), and Eduardo C. De Quintos, Jr., Respondents.
FACTS
Eduardo De Quintos, Jr. filed a petition to declare his marriage to Catalina Delos Santos-De Quintos null and void under Article 36 of the Family Code, citing her psychological incapacity. Eduardo testified that Catalina abandoned household duties, refused sexual relations, squandered his overseas remittances through gambling, and eventually abandoned the conjugal home to live with another man. In support, he presented the neuro-psychiatric evaluation of Dr. Annabelle Reyes, who diagnosed Catalina with Borderline Personality Disorder, characterizing it as an incurable condition causing immaturity that rendered her psychologically incapacitated to fulfill marital obligations. Catalina, while not appearing at trial, submitted an answer admitting her psychological incapacity but contesting some factual allegations.
The Regional Trial Court granted the petition, heavily relying on the expert opinion of Dr. Reyes. The Court of Appeals affirmed the decision, holding that the psychological incapacity was medically identified and sufficiently proven.
ISSUE
Whether the Court of Appeals erred in affirming the declaration of nullity of marriage, as the evidence failed to prove Catalina’s psychological incapacity in accordance with the stringent requirements of Article 36 of the Family Code and applicable jurisprudence.
RULING
The Supreme Court GRANTED the petition, REVERSED the Court of Appeals, and DISMISSED the petition for nullity. The Court held that the evidence failed to establish psychological incapacity as defined in Republic v. Molina. The legal logic requires that the incapacity must be (a) grave, (b) rooted in the party’s psyche prior to the marriage, and (c) incurable. Mere difficulty, refusal, or neglect in performing marital duties, or patterns of misbehavior like abandonment, gambling, or infidelity, do not automatically equate to psychological incapacity absent clear evidence of a debilitating psychological condition existing at the inception of the marriage.
Here, Dr. Reyes’ evaluation was deemed insufficient. Her conclusion was primarily based on Eduardo’s one-sided narratives and tests administered only on Catalina. The expert failed to ascertain the root cause of the alleged disorder or to demonstrate that its grave and incurable nature existed at the time of the marriage celebration in 1977. The cited behaviors—neglect, gambling, and infidelity—manifested years later and were not shown to be manifestations of a psychological illness existing at the marriage’s inception. Consequently, the State correctly argued that the evidence merely depicted marital strife and Catalina’s failure to meet expectations, not the juridical concept of psychological incapacity that nullifies a marriage from the beginning.