G.R. No. 136490; October 19, 2000
Brenda B. Marcos, petitioner, vs. Wilson G. Marcos, respondent.

FACTS

Petitioner Brenda Marcos sought the declaration of nullity of her marriage to respondent Wilson Marcos under Article 36 of the Family Code, citing his psychological incapacity. The Regional Trial Court granted the petition, finding that Wilson’s failure to find gainful employment to support the family and his violent and abusive behavior towards Brenda and their children constituted psychological incapacity. The trial court relied on the psychological evaluation of Brenda by Dr. Natividad Dayan and a social worker’s case study, though Wilson did not submit to any examination.
The Court of Appeals reversed the RTC decision, declaring the marriage valid. The CA held that the totality of evidence failed to prove psychological incapacity as defined in the Molina guidelines. It emphasized that the alleged causes—unemployment and violent conduct—were not shown to be grave, rooted in Wilson’s psychological makeup, or incurable. The CA also initially suggested a personal medical examination of the respondent was a prerequisite, a point later corrected.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s declaration of nullity based on a finding that psychological incapacity was not sufficiently proven.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals, with a clarification on the evidentiary requirement. The Court reiterated that psychological incapacity must be characterized by gravity, juridical antecedence, and incurability. It must be a serious malady that renders the spouse incapable of fulfilling the basic marital obligations.
The Court held that the evidence presented—Wilson’s unemployment, quarrelsomeness, and violent acts—did not meet the stringent Molina standards. These behaviors, while indicative of marital strife, were not proven to be manifestations of a psychological disorder existing at the time of the marriage and incurable in nature. They may constitute grounds for legal separation but not for nullity. Crucially, the Court clarified that while expert testimony is valuable, a personal medical examination of the respondent spouse is not an absolute requirement. Psychological incapacity can be established by the totality of evidence, including testimonies on his or her behavior. However, in this case, the totality of evidence still fell short of proving a psychological condition that nullified the marriage from its inception.