G.R. No. 209278 , September 15, 2021
IRENE CONSTANTINO DATU, PETITIONER, VS. ALFREDO FABIAN DATU, RESPONDENT.

FACTS

Alfredo Fabian Datu filed a Complaint for declaration of nullity of his marriage to Irene Constantino Datu on the ground of his psychological incapacity. The parties were married on December 15, 1980. Alfredo testified that he was discharged from the United States Navy in 1978 for medical and psychiatric reasons, having been diagnosed with schizophrenia. He claimed Irene was materialistic, a nagger, and did not submit to him. He believed his utterances came from God, refused to work to fulfill God’s prophecy, and left Irene to live with his maid. His aunt corroborated his testimony and described Irene negatively. A clinical psychologist, Martha Johanna D. Dela Cruz, evaluated Alfredo and found he suffered from schizophrenia, paranoid type, with impaired judgment, and that his condition was incurable. Irene declined a psychological evaluation. Irene testified that they separated because Alfredo found another woman, that he failed to provide support despite an agreement, and that she relied on benefits from the U.S. Veterans Affairs due to Alfredo’s schizophrenia. She admitted not wanting the marriage voided to continue receiving financial support. The Regional Trial Court voided the marriage, finding Alfredo psychologically incapacitated due to his schizophrenia, which existed before the marriage and rendered him incapable of fulfilling essential marital obligations. The Court of Appeals affirmed the decision.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision declaring the marriage between Irene and Alfredo null and void on the ground of psychological incapacity.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court held that psychological incapacity under Article 36 of the Family Code is a legal concept, not strictly medical. It is sufficient to prove that an enduring aspect of a spouse’s personality renders them incapable of performing essential marital obligations, and it is no longer necessary to root the incapacity in a particular psychological illness. The evidence, including Alfredo’s pre-marriage discharge from the U.S. Navy due to schizophrenia, expert psychological evaluations confirming his chronic and grave psychotic disorder, and his own testimony demonstrating delusions and an inability to perform marital duties such as cohabitation, fidelity, and support, clearly established his psychological incapacity. The fact that the incapacity existed at the time of the marriage and is incurable was also proven. Irene’s motive for opposing the petition (financial support) did not negate the factual and legal basis for nullity. The trial court’s findings were supported by the evidence and accorded respect.