G.R. No. 150677 ; June 5, 2009
Renato Reyes So, Petitioner, vs. Lorna Valera, Respondent.

FACTS

Petitioner Renato Reyes So filed a petition to declare his marriage to respondent Lorna Valera null and void under Article 36 of the Family Code (psychological incapacity). The parties had a 19-year common-law relationship before marrying in 1991 and had three children. So alleged that Valera failed to fulfill essential marital obligations: she refused cohabitation and intimacy, was unloving and disrespectful, interfered detrimentally with his business, locked him out of their home, and ultimately expelled him and declared she no longer loved him. Valera did not file an answer. The Regional Trial Court (RTC) granted the petition, relying heavily on the psychological evaluation of Dr. Cristina Rosello-Gates, who concluded Valera had a Narcissistic Personality Disorder that was grave, incurable, and pre-existing.
The Court of Appeals (CA) reversed the RTC’s decision. The appellate court found the evidence insufficient to prove psychological incapacity. It held that Dr. Gates’s findings were primarily based on information provided solely by So, lacked corroborative evidence, and failed to establish that Valera’s alleged condition was medically or clinically identified as a psychological illness that existed at the inception of the marriage and was incurable.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s declaration of nullity based on the respondent’s alleged psychological incapacity.

RULING

The Supreme Court denied the petition and affirmed the CA decision, upholding the validity of the marriage. The legal logic rests on the stringent requirements for nullity under Article 36 as established in Republic v. Molina. Psychological incapacity must be a grave, juridically antecedent mental condition that renders a spouse truly incapable of fulfilling basic marital obligations. The Court found that the petitioner failed to meet the burden of proof. Dr. Gates’s report was fundamentally flawed because her diagnosis was derived almost exclusively from the petitioner’s uncorroborated narrations, with no personal examination of the respondent. This rendered the assessment unreliable and insufficient to prove a pre-existing, grave, and incurable psychological disorder. The behaviors described, such as constant fighting, resentment, and refusal to reconcile, constitute mere marital conflicts, refusal, or difficulty, not the pathological incapacity required by law. The State’s interest in preserving marriage necessitates that nullity be decreed only upon clear, convincing, and categorical evidence of a psychological illness, which was absent in this case.