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

FACTS

Mario Victor M. Andal and Rosanna L. Tan married on December 16, 1995. They had one daughter, Ma. Samantha, born on July 27, 1996. They separated in 2000. In 2001, Mario filed a petition for custody of their daughter. In 2003, Rosanna filed a petition for declaration of nullity of marriage based on Mario’s psychological incapacity. The cases were consolidated.
Rosanna alleged that during their courtship, Mario exhibited erratic behavior, including unexplained absences and financial irresponsibility. After marriage, Mario displayed emotional immaturity, irresponsibility, irritability, and psychological imbalance. He would leave home for days, sleep excessively, and was hyperactive at night. He admitted to using marijuana and later shabu, claiming it helped him cope with work pressure. He failed to assist Rosanna after childbirth, showed paranoia, and made large, unauthorized cash advances from Rosanna’s construction firm, Design and Construction Matrix, leading to its financial ruin. During their daughter’s hospitalization for dengue, Mario interfered with medical care and neglected the child. In November 1998, he attempted to take their daughter away without explanation. He was later committed for detoxification at Medical City, where tests confirmed drug use, but he was not admitted to a rehabilitation center. Rosanna presented a psychologist’s report diagnosing Mario with Narcissistic Personality Disorder and Antisocial Personality Disorder, which were deemed grave and incurable.
The Regional Trial Court granted the petition for nullity, declaring the marriage void due to Mario’s psychological incapacity and awarding sole custody of Ma. Samantha to Rosanna. The Court of Appeals reversed this decision, finding the psychological report insufficient to prove Mario’s incapacity was grave, incurable, and existing at the time of marriage.

ISSUE

Whether the Court of Appeals erred in reversing the Regional Trial Court’s decision that declared the marriage void on the ground of psychological incapacity under Article 36 of the Family Code.

RULING

The Supreme Court granted the petition, reversed the Court of Appeals’ decision, and reinstated the Regional Trial Court’s decision declaring the marriage void ab initio due to Mario’s psychological incapacity.
The Court abandoned the strict guidelines set in Republic v. Court of Appeals and Molina (Molina guidelines). It held that the Molina guidelines, while instructive, were not absolute requirements. The Court restated the doctrine of psychological incapacity as follows: Psychological incapacity refers to a personal condition that prevents a spouse from fulfilling essential marital obligations. It must be characterized by gravity, juridical antecedence, and incurability. The incapacity must be rooted in the spouse’s personality structure, existing at the time of marriage, and must be serious enough to bring about the disability to assume essential marital obligations. The evidence must show a natal or supervening disabling factor that effectively incapacitates the spouse. The condition need not be a mental or personality disorder, but any illness severe enough to prevent compliance with marital duties. The evidence required is preponderance of evidence, and the totality of evidence must be considered. Expert testimony, while helpful, is not mandatory. The incapacity need not be medically or clinically identified; it can be established through the spouse’s behavior. The Court emphasized a case-to-case basis, focusing on the parties’ behavior during marriage to determine incapacity.
Applying this restated doctrine, the Court found Mario psychologically incapacitated. His persistent drug use, financial irresponsibility, neglect of family duties, paranoia, and personality disorders, as evidenced by his behavior throughout the marriage, constituted a grave and incurable condition that existed at the time of marriage and prevented him from fulfilling his essential marital obligations. The Court affirmed the award of sole custody of Ma. Samantha to Rosanna, noting the child was already emancipated by age at the time of the decision.