G.R. No. 208790 ; January 21, 2015
GLENN VIÑAS, Petitioner, vs. MARY GRACE PAREL-VIÑAS, Respondent.

FACTS

Petitioner Glenn Viñas filed a petition to declare his marriage to respondent Mary Grace Parel-Viñas null and void on the ground of her alleged psychological incapacity under Article 36 of the Family Code. Glenn alleged that Mary Grace exhibited traits of insecurity, extreme jealousy, and a propensity for nightlife, drinking, and smoking, even during her pregnancy, which resulted in their infant’s death. He claimed she refused household chores, was unremorseful, self-centered, and eventually left their home in 2006 to work in Dubai, where she entered a new relationship. Glenn presented a psychological evaluation report from Dr. Nedy Tayag, who diagnosed Mary Grace, based on interviews with Glenn and a cousin, with Narcissistic Personality Disorder with anti-social traits. The report described the condition as grave, permanent, and incurable, rooted in her childhood within a dysfunctional family.
The Regional Trial Court (RTC) granted the petition and declared the marriage null and void. However, the Court of Appeals (CA) reversed this decision, finding the evidence insufficient to prove psychological incapacity. The CA emphasized that the psychologist never personally examined Mary Grace and that the evidence failed to establish the juridical antecedence, gravity, and incurability required by jurisprudence.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s decision and in ruling that the evidence presented was insufficient to prove Mary Grace’s psychological incapacity to comply with essential marital obligations.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The Court reiterated the strict guidelines established in Molina and Tan-Andal for declaring a marriage null under Article 36. Psychological incapacity must be shown to be: (1) juridically antecedent to the marriage, (2) grave or serious, and (3) incurable. The evidence presented by Glenn, primarily the psychologist’s report, was deemed insufficient. The diagnosis was based solely on information provided by Glenn and his cousin, as Mary Grace was not personally examined. This rendered the assessment unreliable for establishing the true root cause, severity, and incurability of her alleged condition.
The Court found that the cited behaviors—such as being carefree, ill-tempered, or enjoying nightlife—did not necessarily constitute psychological incapacity but could be attributed to mere refusal, difficulty, or neglect in performing marital duties. The alleged familial background (e.g., being the eldest child with a lenient upbringing and an overseas contract worker father) was insufficient to conclusively prove a psychologically incapacitating disorder existing at the time of the marriage ceremony. The totality of evidence failed to meet the clear and convincing standard required to nullify a marriage, which is considered a sacred institution. Thus, the marriage between Glenn and Mary Grace remains valid and subsisting.