GR 161793; (February, 2009) (Digest)
G.R. No. 161793 February 13, 2009
EDWARD KENNETH NGO TE, Petitioner, vs. ROWENA ONG GUTIERREZ YU-TE, Respondent, REPUBLIC OF THE PHILIPPINES, Oppositor.
FACTS
Petitioner Edward Kenneth Ngo Te and respondent Rowena Ong Gutierrez Yu-Te met in college in January 1996. After three months, they eloped to Cebu in March 1996 but returned to Manila in April 1996 after exhausting their funds. On April 23, 1996, they were married. Edward alleged that Rowena’s uncle brought them to court to get married, he was treated like a prisoner at her uncle’s house, and he was threatened with guns. Edward escaped after a month and returned to his parents. In June 1996, after a conversation where Rowena refused to live with his parents and insisted on getting his inheritance to live separately, they agreed to part ways. Edward filed a petition for annulment of marriage on January 18, 2000, on the ground of Rowena’s psychological incapacity. A clinical psychologist examined Edward and concluded both parties were psychologically incapacitated, describing them as emotionally immature and recklessly impulsive, with the marriage being weakly-founded and caused by unreadiness for commitment and young age.
ISSUE
Whether the marriage between petitioner and respondent is void on the ground of psychological incapacity under Article 36 of the Family Code.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision which upheld the Regional Trial Court’s dismissal of the petition for annulment. The Court held that the totality of evidence failed to prove that respondent’s condition constituted psychological incapacity. The psychologist’s findings, which were based solely on the petitioner’s narration, described traits of immaturity, impulsivity, and self-centeredness, but these did not rise to the level of a grave, severe, and incurable psychological illness that existed at the time of the marriage. The Court emphasized that Article 36 requires a psychological condition that is medically or clinically identified, grave, incurable, and existing at the time of the marriage celebration. The evidence presented, including the report stating the marriage was “weakly-founded” and caused by “unreadiness to commitment and their young age,” did not meet this strict standard. The Court reiterated that psychological incapacity must be more than just irreconcilable differences, marital unhappiness, or emotional immaturity.