GR 149498; (May, 2004) (Digest)
G.R. No. 149498 ; May 20, 2004
Republic of the Philippines, petitioner, vs. Lolita Quintero-Hamano, respondent.
FACTS
Respondent Lolita Quintero-Hamano filed a petition to declare her marriage to Japanese national Toshio Hamano null and void on the ground of his psychological incapacity. They were married in January 1988. Merely a month after the marriage, Toshio returned to Japan, promising to send support and return for Christmas. He sent money for only two months and then ceased all communication. Despite Lolita’s efforts to contact him, Toshio never responded and even visited the Philippines without seeing his family. The trial court granted the petition, finding Toshio’s abandonment and indifference to be a clear manifestation of psychological incapacity. The Court of Appeals affirmed, distinguishing the case from the Molina guidelines because it involved a “mixed marriage.”
ISSUE
Whether the respondent successfully proved the psychological incapacity of her spouse, Toshio Hamano, under Article 36 of the Family Code.
RULING
The Supreme Court REVERSED the appellate decision and DENIED the petition for nullity. The Court held that respondent failed to prove psychological incapacity as defined in Santos v. CA and Republic v. Molina. Mere abandonment, failure to provide support, and neglect of familial duties, while indicative of refusal or neglect, do not per se constitute psychological incapacity. The law requires proof of a grave, severe, and incurable psychological illness existing at the time of the marriage that completely incapacitates a person from fulfilling marital obligations.
The Court explicitly rejected the appellate court’s distinction for “mixed marriages,” ruling that the guidelines for proving psychological incapacity apply uniformly regardless of the spouse’s nationality. The evidence presented only showed Toshio’s pattern of irresponsible and insensitive behavior, not a psychological disorder rooted in his personality. Without expert testimony or evidence demonstrating a psychological or psychiatric condition that is medically or clinically identified as grave and incurable, his actions remain in the realm of difficulty, refusal, or neglect—grounds for legal separation, not nullity. The State’s policy to protect marriage as an inviolable institution necessitates strict adherence to the Molina standards.