G.R. No. 168335 ; June 6, 2011
Republic of the Philippines, Petitioner, vs. Nestor Galang, Respondent.

FACTS

On March 9, 1994, respondent Nestor Galang and Juvy Salazar contracted marriage. They had one child, Christopher. On August 4, 1999, the respondent filed a petition for the declaration of nullity of his marriage under Article 36 of the Family Code, alleging that Juvy was psychologically incapacitated to perform her essential marital obligations. He claimed she was a kleptomaniac and a swindler who stole his ATM card and his parents’ money, borrowed money from relatives under false pretenses (e.g., claiming their child was hospitalized), was lazy and irresponsible, neglected their child, and was addicted to gambling (mahjong and kuwaho). The respondent presented his own testimony and that of psychologist Anna Liza S. Guiang. The psychologist, who only examined the respondent and not Juvy (as Juvy did not respond to a request for an interview), issued a Psychological Report concluding that Juvy suffered from personality and behavioral disorders characterized by irresponsibility, laziness, gambling dependency, and stealing, which were grave, antecedent, and incurable. The Regional Trial Court (RTC) of Angeles City granted the petition and declared the marriage null and void. The Court of Appeals (CA) affirmed the RTC decision. The Republic of the Philippines, through the Office of the Solicitor General, filed the present petition, arguing that the totality of evidence was insufficient to prove psychological incapacity under the guidelines set in Molina and that the respondent failed to establish the juridical antecedence, gravity, and incurability of Juvy’s condition.

ISSUE

Whether the totality of evidence presented by the respondent is sufficient to prove that Juvy Salazar was psychologically incapacitated to comply with the essential obligations of marriage under Article 36 of the Family Code.

RULING

No. The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the decisions of the Court of Appeals and the Regional Trial Court, and DISMISSED the petition for declaration of nullity of marriage. The Court held that the evidence failed to prove Juvy’s psychological incapacity with the required degree of certainty under the guidelines in Republic v. Court of Appeals and Molina and the more recent interpretation in Ngo Te v. Yu-Te.
The Court emphasized that psychological incapacity must be more than just irreconcilable differences, personality conflicts, or emotional immaturity. It must be a serious psychological illness that is grave, juridically antecedent, and incurable, and must clearly prevent the spouse from fulfilling the basic marital obligations. The psychologist’s report was found to be insufficient and unreliable because it was based solely on the respondent’s accounts and the psychologist never personally examined Juvy. The report’s conclusions were merely a rehash of the respondent’s allegations (laziness, gambling, stealing, neglect) and did not identify a specific, clinically diagnosed psychological disorder rooted in Juvy’s history prior to the marriage. The behaviors described, while irresponsible, did not necessarily constitute a psychological incapacity of a grave and incurable nature that existed at the inception of the marriage. The evidence showed marital strife and Juvy’s failure to meet expectations, but not a psychological condition that completely disabled her from understanding and performing her marital duties. Therefore, the marriage between Nestor Galang and Juvy Salazar remains valid and subsisting.