G.R. No. 157649 ; November 12, 2012
ARABELLE J. MENDOZA, Petitioner, vs. REPUBLIC OF THE PHILIPPINES and DOMINIC C. MENDOZA, Respondents.

FACTS

Petitioner Arabelle J. Mendoza sought the declaration of nullity of her marriage to respondent Dominic C. Mendoza under Article 36 of the Family Code, citing his psychological incapacity. The parties married in June 1991. Arabelle alleged that Dominic was habitually irresponsible, dependent on parental support, and failed to contribute to family expenses despite her working multiple jobs. She detailed his infidelity, deceit involving blank checks, criminal acts of estafa and violation of B.P. 22 leading to incarceration, and threats of suicide. Dominic did not participate in the trial. The Regional Trial Court granted the petition, relying heavily on the psychiatric evaluation of Dr. Rocheflume Samson, which concluded Dominic had an antisocial personality disorder rooted in childhood, rendering him incapable of marital obligations.
The Republic, through the Office of the Solicitor General, appealed. The Court of Appeals reversed the RTC decision, finding the evidence insufficient to prove the required elements of psychological incapacity. The CA held that the alleged acts, while indicative of difficulty, irresponsibility, and neglect, did not constitute the grave, incurable, and antecedent psychological incapacity contemplated by law. Arabelle elevated the case to the Supreme Court via a petition for review.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s decision and in ruling that the evidence failed to prove respondent Dominic C. Mendoza’s psychological incapacity to comply with essential marital obligations.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court reiterated that for a marriage to be declared null under Article 36, the psychological incapacity must be shown to be grave, juridically antecedent to the marriage, and incurable. The totality of evidence must convincingly establish a serious illness that completely deprives the spouse of the capacity to understand and fulfill the basic marital obligations of cohabitation, mutual support, love, and respect.
The Court found that the evidence presented, including the psychiatrist’s testimony, merely established Dominic’s pattern of irresponsibility, immaturity, infidelity, and criminal behavior. While these traits made the marriage dysfunctional, they were not proven to be manifestations of a psychological disorder so severe as to constitute a true incapacity to assume marital duties from the very beginning. The expert’s conclusion of a personality disorder was not sufficiently rooted in facts demonstrating its existence prior to the marriage. The acts described, though regrettable, were more indicative of refusal or neglect, not an incurable psychological condition. The petition failed to discharge the burden of proof required by the guidelines in Republic v. Molina.