G.R. No. 210548 , March 02, 2020
Ana Liza Asis Castro, Petitioner, vs. Joselito O. Castro, Respondent.

FACTS

Petitioner Ana Liza Asis Castro filed a petition for declaration of nullity of her marriage to respondent Joselito O. Castro on the ground of psychological incapacity under Article 36 of the Family Code. She also prayed for custody of their children and monthly support. The parties were married on June 4, 1989, and had three children. Petitioner alleged that respondent was unemployed at the start of the marriage, was possessive and jealous, had violent outbursts, was irresponsible, and emotionally tortured their children. A specific incident where respondent cursed and pinned their daughter against a wall prompted petitioner to drive him away from the conjugal home. To support her claim, petitioner presented the testimony and medical assessment of clinical psychologist Dr. Natividad Dayan, who concluded that respondent was psychologically incapacitated, suffering from a Personality Disorder Not Otherwise Specified with Paranoid Antisocial Personality Disorder, characterized by pathological suspiciousness, mistrust, aggressiveness, violent behavior, and lack of empathy. Dr. Dayan traced the root cause to parental overindulgence and exposure to his father’s and siblings’ violent behavior. Respondent, in his Answer, also sought a declaration of nullity but claimed it was petitioner who was psychologically incapacitated. The Regional Trial Court (RTC) dismissed the petition, upholding the validity of the marriage, finding the evidence insufficient to prove respondent’s psychological incapacity was grave and serious, and noting the parties lived together for 20 years. The Court of Appeals (CA) affirmed the RTC decision, disputing the one-sided findings of Dr. Dayan, who did not personally examine the respondent.

ISSUE

Whether or not petitioner and respondent’s marriage should be declared null on the basis of psychological incapacity under Article 36 of the Family Code.

RULING

No. The Supreme Court denied the petition and affirmed the CA Decision and Resolution. The Court held that the totality of evidence presented by the petitioner failed to prove that respondent’s psychological incapacity was grave, serious, incurable, and rooted in his history antedating the marriage, as required by jurisprudence. The Court found that Dr. Dayan’s assessment was based solely on interviews with the petitioner and her children, without personal examination of the respondent, and lacked corroborative evidence from other sources like relatives or friends. The Court emphasized that the sanctity of marriage is constitutionally guarded and that mere marital conflicts, irreconcilable differences, or emotional immaturity do not constitute psychological incapacity. The alleged acts of respondent, such as jealousy, violent outbursts, and irresponsibility, were deemed insufficient to establish a psychological disorder that completely disabled him from fulfilling his essential marital obligations. The Court also ordered the remand of the case to the RTC for the reopening of trial solely for the purpose of determining the proper amount of support for the children, as the issue of support was factual and required further reception of evidence.