G.R. No. 201988 October 11, 2017
MARIA VICTORIA SOCORRO LONTOC-CRUZ, Petitioner vs. NILO SANTOS CRUZ, Respondent

FACTS

Petitioner Marivi Lontoc-Cruz filed a petition to declare her marriage to respondent Nilo Santos Cruz null and void under Article 36 of the Family Code, alleging psychological incapacity on both their parts. The marriage, which began in 1986 and produced two children, was described as dysfunctional. Marivi claimed Nilo suffered from an “inadequate personality disorder related to masculine strivings associated with unresolved oedipal complex,” citing his infidelity, lack of commitment, financial secrecy, lack of sexual intimacy for over a decade, and treating her as a mere housemate. Nilo, in his answer, conceded that both parties had psychological disorders and contributed to the marriage’s failure, alleging Marivi had a volatile temperament, was disrespectful, and made impulsive decisions. Both parties presented expert psychologists who diagnosed each spouse with personality disorders. The Regional Trial Court denied the petition, a decision affirmed by the Court of Appeals.

ISSUE

Whether the totality of evidence presented sufficiently proves that either or both parties were psychologically incapacitated to comply with the essential marital obligations at the time of the marriage’s celebration, warranting a declaration of nullity under Article 36.

RULING

The Supreme Court DENIED the petition and affirmed the lower courts’ decisions, declaring the marriage valid. The Court held that the evidence failed to meet the stringent requirements for psychological incapacity as established in jurisprudence. While both parties exhibited marital strife, irreconcilable differences, and personality conflicts, these did not constitute the grave, severe, and incurable psychological condition contemplated by Article 36. The expert testimonies and diagnoses, while identifying personality disorders, did not convincingly establish that these conditions were already juridically antecedent, grave, and incurable at the time of the wedding in 1986. The behaviors described, such as Nilo’s alleged infidelity and lack of emotional support and Marivi’s alleged volatility, were manifestations of marital conflict and not conclusive proof of a psychological defect that completely deprived them of the capacity to understand and fulfill the basic obligations of marriage. The Court emphasized that Article 36 is not a remedy for failed marriages but a legal recognition of a pre-existing incapacity. The evidence merely showed that the marriage had broken down, which is a ground for legal separation, not nullity. The parties’ own admissions and the expert opinions were insufficient to overturn the factual findings of the trial court, which were accorded great respect.