G.R. No. 127263 . April 12, 2000.
FILIPINA Y. SY, petitioner, vs. THE HONORABLE COURT OF APPEALS, THE HONORABLE REGIONAL TRIAL COURT, SAN FERNANDO, PAMPANGA, BRANCH XLI, and FERNANDO SY, respondents.

FACTS

Petitioner Filipina Y. Sy and private respondent Fernando Sy were married in 1973. They had two children and operated a business together. In 1983, Fernando left the conjugal dwelling. Subsequently, Filipina filed various actions against him, including a petition for separation of property (granted in 1987) and a petition for legal separation (granted in 1991 on grounds of repeated physical violence and sexual infidelity). Fernando was also convicted of slight physical injuries against Filipina in 1990. In 1992, Filipina filed a new petition seeking a declaration of absolute nullity of marriage on the ground of psychological incapacity under Article 36 of the Family Code.
She alleged that Fernando’s psychological incapacity was manifested by his habitual alcoholism, refusal to cohabit, sexual infidelity, physical violence, and abandonment. She contended this incapacity existed at the time of the marriage’s celebration. Both the Regional Trial Court and the Court of Appeals denied the petition. The appellate court found the evidence insufficient to prove psychological incapacity, noting the couple lived harmoniously for nearly ten years before their separation in 1983, which indicated the alleged incapacity was not pre-existing.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s denial of the petition for declaration of absolute nullity of marriage based on psychological incapacity.

RULING

The Supreme Court denied the petition and affirmed the assailed decisions. The legal logic is anchored on the strict interpretation of psychological incapacity under Article 36, as elucidated in Republic v. Molina. The Court emphasized that not every instance of marital difficulty, neglect, abuse, or abandonment constitutes psychological incapacity. The incapacity must be a grave, serious, and incurable psychological condition that renders a spouse truly incapable of fulfilling the essential marital obligations, and it must be shown to have existed at the time of the marriage ceremony.
The Court ruled that the acts cited by Filipina—Fernando’s abandonment, infidelity, violence, and alcoholism—while indicative of marital strife and grounds for legal separation, do not per se equate to the psychological incapacity contemplated by law. Crucially, the evidence failed to establish that these manifestations were rooted in a psychological disorder existing at the inception of the marriage in 1973. The fact that the parties cohabited and managed a family business for a decade before their separation strongly negates the claim of an antecedent incapacity. The burden of proof lies with the plaintiff, and Filipina did not present expert testimony or clear evidence to prove a pre-marital, grave, and incurable psychological condition. Thus, the marriage, celebrated with all legal requisites, remains valid and protected by state policy.