G.R. No. 167206 November 18, 2005
Jaime F. Villalon, Petitioner, vs. Ma. Corazon N. Villalon, Respondent.

FACTS

Petitioner Jaime Villalon filed a petition for the annulment of his marriage to respondent Ma. Corazon Villalon on the ground of his own psychological incapacity under Article 36 of the Family Code. He alleged that his incapacity, existing even prior to the marriage, manifested through his chronic refusal to maintain harmonious family relations, immaturity, irresponsibility, and a persistent desire for other women, which he termed a “Casanova Complex.” To support his claim, he presented the testimony of a clinical psychologist, Dr. Natividad Dayan, who diagnosed him with “Narcissistic Histrionic Personality Disorder.”
Respondent opposed the petition, asserting that their 18-year marriage was generally fruitful and that their conflicts were normal. She presented a psychiatrist, Dr. Cecilia Villegas, who critiqued the methodology of petitioner’s expert, stating that a full evaluation required a team approach. The trial court granted the petition and declared the marriage null and void. The Court of Appeals reversed this decision, prompting petitioner to elevate the case to the Supreme Court.

ISSUE

Whether the petitioner has sufficiently proven his psychological incapacity to comply with the essential marital obligations, warranting the declaration of nullity of his marriage.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, upholding the validity of the marriage. The Court applied the guidelines established in Republic v. Court of Appeals (Molina), which require that the psychological incapacity must be characterized by gravity, juridical antecedence, and incurability. The incapacity must be a serious malady that effectively incapacitates a person from accepting and fulfilling the fundamental duties of marriage.
The Court found that the petitioner failed to meet this stringent standard. His evidence merely established a pattern of marital dissatisfaction, infidelity, and a refusal to continue the marriage, which he attributed to his wife’s withdrawn nature and his own discontent. The expert diagnosis presented was deemed insufficient to prove a psychological disorder that was grave, rooted in his personality prior to the marriage, and truly incapacitating. The Court emphasized that psychological incapacity under Article 36 is not a catch-all provision for failed marriages, marital refusal, neglect, or difficulty. The State’s policy is to preserve the sanctity of marriage, and any doubt must be resolved in favor of its validity. Consequently, the petitioner’s loss of love and refusal to fulfill marital obligations did not constitute the psychological incapacity contemplated by law.