G.R. No. 209180 and 209253 February 24, 2016
Republic of the Philippines vs. Reghis M. Romero II and Olivia Lagman Romero; Olivia Lagman Romero vs. Reghis M. Romero II

FACTS

Reghis M. Romero II and Olivia Lagman Romero were married in 1972. Reghis testified that he married primarily to please Olivia’s parents, who had been kind to him, and not out of love. He felt unprepared for marriage as his focus was on finishing his studies and supporting his own family. The marriage was turbulent, marked by violent fights and estrangement. Reghis became engrossed in his career as a medical representative, neglecting his family, which led to Olivia’s complaints. The couple eventually separated in 1986.
In 1998, Reghis filed a petition to declare the marriage null and void on the ground of his psychological incapacity under Article 36 of the Family Code. He presented a clinical psychologist, Dr. Valentina Nicdao-Basilio, who diagnosed him with Obsessive Compulsive Personality Disorder (OCPD). The expert testified that this disorder caused Reghis to have a strong obsession for his work to the exclusion of his marital and parental duties, that it existed prior to the marriage, and was incurable. Olivia, who failed to present evidence due to her counsel’s absence, and the Republic, through the OSG, opposed the petition.

ISSUE

Whether the totality of evidence presented sufficiently proves Reghis’s psychological incapacity to comply with the essential marital obligations, warranting a declaration of nullity under Article 36 of the Family Code.

RULING

Yes, the Supreme Court affirmed the lower courts’ decisions declaring the marriage null and void. The Court applied the guidelines established in Molina and subsequent jurisprudence, emphasizing that psychological incapacity must be characterized by gravity, juridical antecedence, and incurability. The Court found that the expert testimony and Reghis’s own narration constituted clear and convincing evidence meeting these criteria.
The legal logic rests on the finding that Reghis’s OCPD was a serious psychological condition that rendered him incapable of fulfilling the basic obligations of marriage, such as mutual love, respect, and cohabitation. His obsessive focus on career and extended family, to the detriment of his marital relationship, was not mere refusal or neglect but a true incapacity rooted in a psychological disorder existing at the time of the wedding. The Court held that the condition was grave as it destroyed the marital partnership, antecedent as it was traceable to his pre-marriage state of mind and priorities, and incurable as confirmed by expert opinion. The defense of res judicata was correctly rejected, as the prior dismissed petitions alleged Olivia’s incapacity, which is a different cause of action from the present case alleging Reghis’s own incapacity.