G.R. No. 184063 ; January 24, 2011
CYNTHIA E. YAMBAO, Petitioner, vs. REPUBLIC OF THE PHILIPPINES and PATRICIO E. YAMBAO, Respondents.

FACTS

Petitioner Cynthia E. Yambao and respondent Patricio E. Yambao were married on December 21, 1968. After 35 years of marriage, petitioner filed a Petition before the Regional Trial Court (RTC) of Makati City on July 11, 2003, seeking the annulment of their marriage on the ground of respondent’s psychological incapacity under Article 36 of the Family Code. Petitioner alleged that from the beginning, their married life was marred by quarrels due to respondent’s inability to fulfill essential marital obligations. She claimed she was the sole breadwinner, while respondent did not hold stable employment, failed in business ventures, gambled, and refused to help care for their children. She also asserted that respondent became excessively jealous, threatened to kill her, and caused her to leave the conjugal home. A psychiatrist concluded respondent was psychologically incapacitated. Respondent denied the allegations, claiming he sought work but was hindered by age and lack of qualifications, that business failures were due to economic crises, and that he did not gamble or threaten petitioner. The RTC dismissed the petition, finding petitioner’s evidence insufficient to prove respondent’s psychological incapacity, noting the marriage lasted over 30 years, they raised three children successfully, respondent was faithful and non-abusive, and his faults like indolence or business failure were not necessarily psychological incapacity. The Court of Appeals affirmed the RTC decision, holding petitioner failed to establish that respondent’s alleged irresponsibility, jealousy, and threats constituted a grave, incurable psychological disorder that existed at the time of the marriage and rendered him incapable of fulfilling marital obligations.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s dismissal of the petition for annulment of marriage, thereby holding that respondent was not psychologically incapacitated under Article 36 of the Family Code.

RULING

The Supreme Court DENIED the petition and AFFIRMED the decisions of the lower courts. The Court held that petitioner failed to prove respondent’s psychological incapacity by clear and convincing evidence. The allegations of respondent’s refusal to work, failure in business, lack of childcare, jealousy, and threats, even if true, constituted mere refusal, neglect, difficulty, or emotional immaturity in complying with marital obligations, not a psychological incapacity that is grave, rooted in the respondent’s history prior to the marriage, incurable, and completely incapacitating him from understanding and performing the essential obligations of marriage. The long duration of the marriage (35 years), the successful raising of children, and the absence of physical abuse indicated a functional marital relationship inconsistent with a finding of psychological incapacity. The expert psychiatric report was deemed insufficiently corroborated and failed to establish the requisite gravity and incurability of the condition. Thus, the marriage remained valid and subsisting.