G.R. No. 203284 , November 14, 2016
Nicolas S. Matudan, Petitioner, vs. Marilyn B. Matudan, Respondent.

FACTS

Petitioner Nicolas S. Matudan sought the declaration of nullity of his marriage to respondent Marilyn B. Matudan under Article 36 of the Family Code, alleging her psychological incapacity. The factual backdrop, as presented in the dissent, is that Marilyn left the conjugal home in 1985 when their children were still minors and subsequently severed all contact with the family for over three decades. Nicolas presented his testimony, the testimony of their daughter Maricel, and the psychological evaluation of Dr. Nedy L. Tayag. Dr. Tayag diagnosed Marilyn, based on collateral information from Nicolas, with Narcissistic Personality Disorder with Antisocial Traits, characterizing her as self-absorbed, deceitful, irresponsible, and remorseless.
The ponencia, or majority decision, denied the petition. It found the evidence insufficient, particularly criticizing the psychological evaluation for being based solely on Nicolas’s account and discounting the daughter’s testimony. The Court of Appeals’ decision, which the Supreme Court affirmed, held that the petitioner failed to prove that Marilyn’s condition was grave, incurable, and existed at the inception of the marriage.

ISSUE

Whether the totality of the evidence presented by the petitioner sufficiently establishes the respondent’s psychological incapacity to comply with essential marital obligations, warranting the declaration of nullity of their marriage.

RULING

In his dissenting opinion, Justice Leonen argued that the petition should be granted. He contended that the lower courts and the ponencia applied an overly restrictive and cruel interpretation of Article 36. The dissent emphasized that the totality of evidence—Marilyn’s abandonment of the family for 31 years, her failure to support and cohabit with her spouse, and her dereliction of parental duties to her minor children—constitutes more than sufficient proof of a grave and incurable psychological condition. Justice Leonen challenged the majority’s rejection of the psychological report, explaining that in psychiatric practice, a diagnosis can validly be based on collateral information from family members when the patient is unavailable. He found Dr. Tayag’s expert testimony, which described a severe and incurable personality disorder, consistent with the undisputed facts of abandonment and irresponsibility. The dissent further invoked the constitutional mandate to protect the dignity of persons and families, suggesting that forcing Nicolas to remain in a long-dead marriage violates this principle. Thus, Justice Leonen concluded that the marriage is void under Article 36 of the Family Code.