G.R. No. 168796 ; April 15, 2010
SILVINO A. LIGERALDE, Petitioner, vs. MAY ASCENSION A. PATALINGHUG and the REPUBLIC OF THE PHILIPPINES, Respondents.

FACTS

Petitioner Silvino Ligeralde sought the declaration of nullity of his marriage to respondent May Patalinghug under Article 36 of the Family Code, alleging her psychological incapacity. He cited her infidelity, irresponsibility, and neglect of marital and parental duties, including an instance where she admitted to sleeping with another man. Despite attempts at reconciliation, May allegedly persisted in her behavior, leading to their separation. Silvino presented a Psychological Evaluation Report by Dr. Tina Nicdao-Basilio, which concluded that May was psychologically incapacitated to fulfill her essential marital obligations, with the condition being grave, incurable, and rooted in her youth.
The Regional Trial Court (RTC) declared the marriage null and void based on this report. However, the Court of Appeals (CA) reversed the RTC decision. The CA ruled that the alleged behaviors—infidelity, immaturity, and irresponsibility—did not per se constitute psychological incapacity as defined by law. It found the psychologist’s report insufficient for failing to clinically identify the root cause of the alleged incapacity and to prove its incurable and antecedent nature.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in reversing the RTC’s decision declaring the marriage null and void.

RULING

The Supreme Court denied the petition and affirmed the CA decision. Procedurally, the Court noted that petitioner erroneously filed a petition for certiorari under Rule 65 instead of a petition for review on certiorari under Rule 45, warranting dismissal on this ground alone. Substantively, the Court found no grave abuse of discretion by the CA. For a successful petition under Rule 65, the petitioner must demonstrate that the lower court acted in a capricious, arbitrary, or whimsical manner equivalent to an evasion of a legal duty. No such abuse was present.
The Court reiterated the stringent requirements for psychological incapacity under Article 36, as established in Republic v. Court of Appeals (Molina). The incapacity must be grave, juridically antecedent, and incurable. The root cause must be medically or clinically identified, alleged, and proven. The evidence must establish its existence at the time of the marriage celebration. The Court held that the petitioner’s evidence, primarily the psychologist’s report, was inadequate. It merely described May’s negative behavior but failed to clinically trace its root cause to a psychological condition existing at the time of the marriage or to conclusively establish its incurability. Allegations of infidelity and irresponsibility, without more, do not equate to the psychological incapacity contemplated by law. Thus, the CA correctly required stricter compliance with the doctrinal guidelines, and its decision was upheld.