G.R. No. 210766, January 8, 2018
MARIA CONCEPCION N. SINGSON a.k.a. CONCEPCION N. SINGSON, Petitioner, vs. BENJAMIN L. SINGSON, Respondent.

FACTS

Petitioner Maria Concepcion Singson filed a petition to declare her marriage to respondent Benjamin Singson null and void under Article 36 of the Family Code, alleging his psychological incapacity. She claimed that from the start of their cohabitation, respondent was dishonest, extravagant, a compulsive gambler, immature, irresponsible, and unfaithful, rendering him completely unable to fulfill his essential marital obligations. Petitioner asserted she became the sole breadwinner. She presented a psychiatric evaluation diagnosing respondent with Pathological Gambling and Personality Disorder, traceable to adolescence, which purportedly incapacitated him from performing marital duties.
Respondent opposed, arguing the alleged incapacity lacked the required gravity, juridical antecedence, and incurability. He contended his actions did not constitute a serious personality disorder but were mere shortcomings or physical illnesses. He emphasized his ability to provide, citing the family home as his capital property, and claimed the petition stemmed from marital dissatisfaction, not psychological incapacity. The Regional Trial Court granted the petition, but the Court of Appeals reversed, finding the evidence insufficient to prove psychological incapacity.

ISSUE

Whether the totality of evidence presented sufficiently proves that respondent was psychologically incapacitated to comply with his essential marital obligations at the time of the marriage celebration, warranting a declaration of nullity under Article 36.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic requires that psychological incapacity under Article 36 must be characterized by (a) gravity—it must be grave enough to bring about the disability to assume essential marital obligations; (b) juridical antecedence—it must be rooted in the history of the party antedating the marriage; and (c) incurability—it must be incurable or beyond the party’s control. Mere difficulty, refusal, or neglect in performing these obligations, or conflicts, immaturity, or irresponsibility, does not constitute psychological incapacity.
The Court found petitioner’s evidence insufficient. The expert diagnosis, while noting respondent’s gambling and personality patterns, failed to conclusively establish that these conditions existed at the inception of the marriage in 1974 with the required gravity and incurability. The psychiatrist’s findings were primarily based on petitioner’s accounts and observations made decades after the wedding. The evidence showed respondent’s irresponsible behavior and failure to provide adequate support, but these constitute neglect of marital responsibilities, not a psychological incapacity that is truly incapacitating, antecedent, and incurable. The root cause was not definitively shown to be a psychological illness existing at the time of marriage. Thus, the marriage cannot be declared void.