G.R. No. 151867 ; January 29, 2004
DAVID B. DEDEL, Petitioner, vs. COURT OF APPEALS and SHARON L. CORPUZ-DEDEL a.k.a. JANE IBRAHIM, Respondents. REPUBLIC OF THE PHILIPPINES, Oppositor-Respondent.

FACTS

Petitioner David Dedel and respondent Sharon Corpuz were married in 1966 and had four children. Petitioner alleged that during the marriage, respondent was an irresponsible wife and mother who engaged in multiple extra-marital affairs, including one with a Jordanian national, Mustafa Ibrahim, whom she later married and with whom she had two children. After Ibrahim left the country, respondent returned to petitioner with her two children by Ibrahim, whom petitioner accepted. However, in 1995, respondent abandoned petitioner to rejoin Ibrahim in Jordan. Petitioner subsequently filed a petition for declaration of nullity of marriage on the ground of respondent’s psychological incapacity under Article 36 of the Family Code.
The Regional Trial Court granted the petition, finding respondent psychologically incapacitated based on the testimony of a psychologist who diagnosed her with Anti-Social Personality Disorder, characterized by infidelity, lack of remorse, and abandonment. The Court of Appeals reversed this decision and dismissed the petition. The Republic, through the Solicitor General, appealed, arguing the absence of a valid ground for nullity and that the trial court erred in declaring the church marriage void and in rendering a decision without the required certification from the Solicitor General as per the Molina guidelines.

ISSUE

Whether the totality of evidence presented is sufficient to sustain a finding that respondent is psychologically incapacitated to perform the essential marital obligations under Article 36 of the Family Code.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic is anchored on the strict interpretation of psychological incapacity as established in Santos v. Court of Appeals and clarified in Republic v. Molina. Psychological incapacity must be a mental condition existing at the time of the marriage celebration, characterized by gravity, juridical antecedence, and incurability. It must demonstrate an utter insensitivity or inability to comprehend and fulfill the basic marital covenants.
The Court ruled that respondent’s alleged infidelity, irresponsibility, and abandonment, while indicative of marital strife, do not per se constitute psychological incapacity as defined by law. These acts are more appropriately classified as grounds for legal separation under Article 55 of the Family Code, not for nullity. The psychologist’s evaluation, which was based largely on petitioner’s accounts and not on a personal examination of respondent, failed to conclusively prove that respondent’s condition was grave, rooted in her pre-marriage personality, and incurable. The totality of evidence did not meet the stringent Molina standards required to nullify a marriage. The Court emphasized that while it sympathizes with petitioner’s predicament, the law on psychological incapacity must be applied strictly to preserve the integrity of marriage as a social institution.