G.R. No. 158896 ; October 27, 2004
JUANITA CARATING-SIAYNGCO, petitioner, vs. MANUEL SIAYNGCO, respondent.

FACTS

Petitioner Juanita Carating-Siayngco and respondent Manuel Siayngco were married on June 27, 1973. After 24 years of marriage, respondent Manuel filed a petition for the declaration of nullity of their marriage on the ground of petitioner Juanita’s psychological incapacity. He alleged that throughout the marriage, she exhibited an over-domineering, selfish, volatile, and bellicose nature; incessantly complained about trivial matters, including his parents and office staff; showed no respect for his position as a judge; yelled, screamed, and threw objects; and provided no moral support for his professional advancement. He claimed this incapacity was rooted in her childhood resentment toward her parents, was present before the marriage, and was permanent and incurable. Petitioner Juanita, in her Answer, denied the allegations, asserted she was a loving wife and mother, claimed respondent Manuel was remiss in his marital obligations and had a paramour, and stated she had a happy childhood. During trial, respondent Manuel presented testimonies and a psychiatric evaluation from Dr. Valentina Garcia, who diagnosed both parties with a “partner relational problem” and “personality disorder not otherwise specified,” concluding they were psychologically incapacitated to comply with marital duties. Petitioner Juanita presented her own testimony and a psychiatric evaluation from Dr. Eduardo Maaba, who found her psychologically capable for marriage. The Regional Trial Court dismissed the petition for nullity. The Court of Appeals reversed this decision, declaring the marriage null and void. Petitioner Juanita elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in reversing the trial court and declaring the marriage between petitioner Juanita and respondent Manuel null and void on the ground of psychological incapacity under Article 36 of the Family Code.

RULING

The Supreme Court REVERSED the decision of the Court of Appeals and REINSTATED the decision of the Regional Trial Court dismissing the petition for declaration of nullity. The Court held that respondent Manuel failed to prove his wife’s psychological incapacity by clear and convincing evidence. The totality of evidence did not establish that petitioner Juanita’s behavior constituted a psychological incapacity that was grave, rooted in her history prior to the marriage, incurable, and completely incapacitated her from complying with the essential marital obligations. The Court found that the alleged acts—such as being temperamental, obsessive about cleanliness, jealous, and critical—did not rise to the level of a psychological disorder that utterly deprived her of the capacity to understand and perform her marital duties. The psychiatric evaluation presented by respondent, which diagnosed both parties with relational problems and personality disorders, was deemed insufficient as it did not conclusively prove that petitioner’s condition met the strict standards for psychological incapacity as defined in jurisprudence (Santos v. Court of Appeals, Republic v. Court of Appeals, and Molina). The Court emphasized that the difficulty of the spouses to relate to each other and fulfill their marital responsibilities does not necessarily equate to psychological incapacity. The marriage was therefore upheld as valid.