G.R. No. 167523 ; June 27, 2008
NILDA V. NAVALES, petitioner, vs. REYNALDO NAVALES, respondent.

FACTS

Reynaldo Navales filed a petition to declare his marriage to Nilda Navales null and void under Article 36 of the Family Code, alleging her psychological incapacity. Reynaldo claimed that after their marriage in 1988, Nilda exhibited flirtatious and promiscuous behavior, such as wearing tight clothing, allowing male clients to touch her, introducing herself as single, and refusing to bear his child to preserve her figure. He presented testimonies from acquaintances and a Psychological Assessment by a clinical psychologist, which diagnosed Nilda with nymphomania and anti-social personality disorder, deemed incurable. Nilda countered that Reynaldo was aware of her past, including an illegitimate child, before marriage. She asserted that Reynaldo was the unfaithful one, that she taught only female students at the YMCA, and that she used her married name, presenting a YMCA certification and PLDT statement as evidence.

ISSUE

Whether the totality of evidence presented by Reynaldo sufficiently establishes Nilda’s psychological incapacity to comply with the essential marital obligations, warranting the declaration of nullity of their marriage under Article 36.

RULING

The Supreme Court REVERSED the lower courts and declared the marriage valid. The legal logic is anchored on the stringent guidelines from the Molina case for proving psychological incapacity. The Court found Reynaldo’s evidence grossly insufficient. The testimonies of lay witnesses merely described Nilda’s alleged behavior but did not conclusively prove a psychological disorder that was grave, rooted in her history prior to the marriage, and incurable. The expert Psychological Assessment was heavily criticized for lacking depth; it was based largely on a one-sided interview with Reynaldo and unverified sources, failing to personally examine Nilda. This rendered the diagnosis speculative and unreliable. The alleged acts, such as using her maiden name or working as an aerobics instructor, do not per se constitute psychological incapacity but may indicate mere marital differences or irreconcilable conflict. The Court emphasized that the State has a strong interest in preserving marriage, and nullity under Article 36 requires clear and convincing evidence of a serious psychological illness existing at the time of the wedding. Reynaldo failed to discharge this burden. The petition for nullity was thus denied.