G.R. No. 165424; June 9, 2009
LESTER BENJAMIN S. HALILI, Petitioner, vs. CHONA M. SANTOS-HALILI and THE REPUBLIC OF THE PHILIPPINES, Respondents.
FACTS
Petitioner Lester Halili filed a petition to declare his marriage to respondent Chona Santos-Halili null and void on the ground of his psychological incapacity under Article 36 of the Family Code. He alleged he entered the civil marriage thinking it was a “joke,” they never cohabited or consummated the union, and he abandoned the relationship after constant quarrels. The Regional Trial Court granted the petition, relying on the testimony and report of his expert witness, Dr. Natividad Dayan, who diagnosed him with a mixed personality disorder, primarily dependent personality disorder, which was grave, incurable, and existed prior to the marriage.
The Court of Appeals reversed the RTC decision, holding that the totality of evidence failed to prove psychological incapacity. The Supreme Court initially denied Halili’s petition for review, affirming the CA. Halili filed a motion for reconsideration, reiterating that the expert testimony sufficiently established his psychological incapacity.
ISSUE
Whether the petitioner’s psychological incapacity, as established by the evidence, particularly expert testimony, is sufficient to declare his marriage null and void.
RULING
The Supreme Court granted the motion for reconsideration and declared the marriage null and void. The Court, guided by its recent ruling in Te v. Yu-Te, emphasized that psychological incapacity must be determined on a case-to-case basis, with courts giving essential consideration to expert opinion on the psychological condition of the parties. The testimony and report of Dr. Dayan comprehensively established that petitioner suffered from dependent personality disorder, characterized by a pervasive pattern of dependent and submissive behavior, lack of self-esteem, fear of criticism, and an inability to make decisions independently.
The Court found this condition was grave, rooted in his dysfunctional family background, and manifested prior to the marriage. It directly resulted in his inability to understand and assume the essential obligations of marriage, as evidenced by his impulsive and jocular motivation for marrying, the non-consummation and non-cohabitation, and his subsequent abandonment of the relationship. The expert convincingly demonstrated the disorder was incurable and juridically antecedent. Therefore, the totality of evidence, anchored on credible expert analysis, met the stringent requirements for declaring a marriage void due to psychological incapacity.