GR 247583; (October, 2021) (Digest)
G.R. No. 247583. October 06, 2021
ROMMEL M. ESPIRITU, PETITIONER, VS. SHIRLEY ANN BOAC-ESPIRITU, RESPONDENT.
FACTS
Petitioner Rommel M. Espiritu filed a petition for declaration of nullity of his marriage to respondent Shirley Ann Boac-Espiritu under Article 36 of the Family Code. They were married on July 18, 2000, and had three children. Petitioner alleged that respondent exhibited signs of psychological incapacity, including refusing sexual relations, constant nagging, hot temper, distrust (e.g., smelling his clothes, checking his phone and wallet), unfounded accusations of infidelity, prioritizing friends over family, and neglect of their children. They separated in 2008. Petitioner presented a clinical psychologist, Dr. Pacita Tudla, who diagnosed respondent with Histrionic Personality Disorder and Paranoid Personality Disorder based on interviews with petitioner and two collateral witnesses (their driver and a neighbor). Dr. Tudla traced these disorders to respondent’s problematic childhood, marked by parental abandonment and lack of proper upbringing. Respondent did not participate in the proceedings. The Regional Trial Court denied the petition, finding the totality of evidence insufficient to prove psychological incapacity, noting that Dr. Tudla’s conclusions were based solely on information from petitioner and his witnesses. The Court of Appeals affirmed the RTC decision.
ISSUE
Whether the totality of evidence presented by petitioner sufficiently proves respondent’s psychological incapacity to warrant the declaration of nullity of their marriage under Article 36 of the Family Code.
RULING
No. The Supreme Court denied the petition and affirmed the decisions of the lower courts. The totality of evidence failed to prove respondent’s psychological incapacity. The expert findings of Dr. Tudla were correctly disregarded as they were based solely on information provided by petitioner and his witnesses, without personal examination of respondent and without corroboration from independent sources familiar with respondent’s background. The alleged behaviors of respondent, such as jealousy, neglect, and refusal of sexual relations, did not constitute psychological incapacity but were mere manifestations of marital conflict, immaturity, or emotional immaturity. The evidence did not establish that respondent’s condition was grave, rooted in her history, incurable, and existing at the time of the marriage celebration. The petition was denied for lack of merit.