G.R. No. 203284, November 14, 2016
Nicolas S. Matudan, Petitioner, vs. Republic of the Philippines and Marilyn B. Matudan, Respondents.

FACTS

Petitioner Nicolas S. Matudan and respondent Marilyn B. Matudan were married in 1976 and had four children. In 1985, Marilyn left to work abroad, after which all contact ceased; she was neither seen nor heard from again. In 2008, Nicolas filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) of Quezon City, alleging Marilyn’s psychological incapacity to fulfill her marital obligations. He presented testimonies from himself, his daughter, and a clinical psychologist, Dr. Nedy L. Tayag, whose report diagnosed Marilyn with a Narcissistic Personality Disorder with Antisocial Traits, described as grave, permanent, and incurable.
The RTC dismissed the petition, finding the evidence insufficient to prove psychological incapacity as defined by law. It noted that Nicolas himself testified to having a happy married life with no fights prior to Marilyn’s departure, attributing the filing solely to her abandonment. The Court of Appeals affirmed the RTC decision, prompting Nicolas to elevate the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s dismissal of the petition for declaration of nullity of marriage based on alleged psychological incapacity.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court reiterated that psychological incapacity under Article 36 of the Family Code must be characterized by gravity, juridical antecedence, and incurability. It must be more than mere refusal, neglect, difficulty, or irresponsibility; it must be a serious mental condition that completely disables a person from understanding and discharging the essential marital obligations.
The Court found that the evidence presented, primarily Dr. Tayag’s report, failed to meet this stringent standard. The psychologist’s conclusions were based largely on interviews with Nicolas and his daughter, not with Marilyn herself, who was absent and unexamined. The factual findings of the RTC, as affirmed by the CA, established that Marilyn’s behavior—characterized by abandonment and lack of support—did not conclusively demonstrate a psychological disorder existing at the inception of the marriage that was grave and incurable. The Supreme Court emphasized its role as not a trier of facts and upheld the lower courts’ factual determinations, which are binding in the absence of compelling reasons to overturn them.