G.R. No. 173138; December 1, 2010
NOEL B. BACCAY, Petitioner, vs. MARIBEL C. BACCAY and REPUBLIC OF THE PHILIPPINES, Respondents.

FACTS

Petitioner Noel Baccay filed a petition to declare his marriage to respondent Maribel Baccay void on the ground of psychological incapacity under Article 36 of the Family Code. Noel alleged that Maribel, whom he married in November 1998 after she claimed to be pregnant, exhibited severe personality defects. He testified that she was consistently aloof and snobbish towards his family, refused to contribute to household expenses, and avoided sexual relations. After a quarrel in February 1999 where Maribel shouted profanities at Noel’s mother, she left the conjugal home and never returned. Noel presented a clinical psychologist who diagnosed Maribel with Narcissistic Personality Disorder, characterizing it as grave, incurable, and juridically antecedent.
The Regional Trial Court granted the petition, finding the psychological incapacity sufficiently proven. On appeal by the Office of the Solicitor General, the Court of Appeals reversed the RTC decision. The CA held that the evidence failed to prove that Maribel’s condition existed at the time of the marriage celebration and that it was of a grave and incurable nature.

ISSUE

Whether the Court of Appeals erred in reversing the RTC and in ruling that the petitioner failed to prove the respondent’s psychological incapacity.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the strict guidelines for psychological incapacity established in Santos v. CA and Republic v. Molina. The Court emphasized that psychological incapacity must be more than mere difficulty, refusal, or neglect to perform marital obligations. It must be a serious, grave, and incurable psychological condition that is medically or clinically identified, rooted in the party’s history antedating the marriage, and utterly incapacitates the person from understanding and fulfilling the essential marital obligations.
The Court found that the evidence presented, primarily Noel’s testimony and the psychologist’s report, was insufficient. The psychologist’s findings were based largely on Noel’s one-sided accounts, without a personal examination of Maribel. The behaviors described—aloofness, financial non-support, and leaving the home—constitute marital neglect or conflict, but do not conclusively establish a psychological disorder of such severity that it completely deprived Maribel of the capacity to assume the basic duties of marriage from its inception. The alleged incapacity was not shown to be truly incurable and existing at the time of the wedding. Thus, the marriage cannot be declared void under Article 36.