G.R. No. 196359, May 11, 2021
Rosanna L. Tan-Andal, Petitioner, vs. Mario Victor M. Andal, Respondent.

FACTS

Petitioner Rosanna L. Tan-Andal married respondent Mario Victor M. Andal on December 16, 1995. During their marriage, Mario exhibited emotional immaturity, financial irresponsibility, irritability, paranoia, and substance abuse. Rosanna filed a Petition for Declaration of Nullity of Marriage, presenting a psychiatrist who diagnosed Mario with Narcissistic Antisocial Personality Disorder and Substance Abuse Disorder with Psychotic Features. The psychiatrist testified that Mario’s disorder was grave, deeply rooted, and impermeable to treatment. The trial court granted the petition, but the Court of Appeals reversed, finding the psychiatric evaluation unscientific and unreliable for being based on second-hand information.

ISSUE

Whether the respondent’s psychological incapacity, as a legal concept, was sufficiently proven to declare the marriage null and void under Article 36 of the Family Code.

RULING

The concurring opinion holds that psychological incapacity is a legal concept, but its root cause can be a mental or personality disorder. The root cause refers to the respondent’s disorder, not his childhood development, and need not be traced exhaustively to upbringing. Psychological incapacity need not be incurable; the textual requirements of Article 36 do not mandate incurability. The totality of evidence, including expert testimony, is considered, and the standard of proof is preponderance of evidence. The opinion agrees with the ponencia’s conclusion that Rosanna sufficiently proved Mario’s psychological incapacity, as his disorders rendered him incapable of fulfilling his essential marital obligations.