G.R. No. 208258. April 27, 2022.
MARIA VICIA CARULLO-PADUA, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES AND JOSELITO PADUA, RESPONDENTS.

FACTS

Petitioner Maria Vicia Carullo-Padua (Maria) and respondent Joselito Padua (Joselito) were married in 1982. On July 17, 1997, Maria filed a petition for declaration of absolute nullity of marriage under Article 36 of the Family Code. She alleged Joselito was psychologically incapacitated to perform his marital obligations, citing his excessive sexual demands, including forced oral and anal sex; attempts to molest her sister, nieces, and household help; misrepresentation of his religion (born-again Christian posing as Roman Catholic) and subsequent insults about her faith; a threat to stab her with a letter opener; failure to provide financial support for her and their child, choosing instead to give half his salary to his parents while living with hers; unemployment for six months in 1985 without seeking work; failure to provide emotional support to their child, occasionally harming him; leaving to work in Italy in 1990 without consultation and later ceasing financial support; and sending a letter in 1992 admitting his faults and deciding to sever ties. Maria presented herself and psychiatrist Dr. Cecilia Villegas as witnesses. Dr. Villegas diagnosed Joselito, based solely on Maria’s narrations, with a personality disorder of a sexual deviant or perversion, traceable to his wretched childhood with a cruel father and overprotective mother, rendering his psychological incapacity grave, serious, and incurable. The Regional Trial Court (RTC) denied the petition, finding the evidence insufficient to overcome the presumption of marriage validity, noting the alleged acts occurred after the marriage and the expert’s findings were based solely on the petitioner’s interested account. The Court of Appeals affirmed the RTC, holding the alleged grounds constituted valid grounds for legal separation, not nullity.

ISSUE

Whether the Court of Appeals erred in affirming the denial of the petition for declaration of nullity of marriage on the ground of psychological incapacity under Article 36 of the Family Code.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the assailed CA Decision. The Court held that Maria failed to prove Joselito’s psychological incapacity by clear and convincing evidence. The totality of evidence did not establish that his alleged sexual deviance, abandonment, and other behaviors were manifestations of a grave, severe, and incurable psychological condition existing at the time of the marriage celebration. Dr. Villegas’s diagnosis was based exclusively on Maria’s uncorroborated narrations, making it insufficient and unreliable. The alleged acts, such as sexual perversion, failure to provide support, and abandonment, while indicative of marital strife, do not per se constitute psychological incapacity as defined by jurisprudence. They are more appropriately grounds for legal separation. The Court reiterated the guidelines in Republic v. Molina and subsequent cases, emphasizing that psychological incapacity must be characterized by gravity, juridical antecedence, and incurability. Maria’s evidence did not meet this stringent standard. The presumption of marriage validity stands.