G.R. No. 214064 , February 6, 2017
MIRASOL CASTILLO, Petitioner, vs. REPUBLIC OF THE PHILIPPINES and FELIPE IMPAS, Respondents.

FACTS

Petitioner Mirasol Castillo sought the declaration of nullity of her marriage to respondent Felipe Impas under Article 36 of the Family Code. The parties married in 1984 and had two children. Mirasol alleged that after thirteen years of marriage, Felipe engaged in multiple extramarital affairs, demonstrated gross irresponsibility, and eventually abandoned the family without support or communication for over ten years. To substantiate her claim of Felipe’s psychological incapacity, Mirasol presented a clinical psychologist who diagnosed Felipe with Narcissistic Personality Disorder. The psychologist’s report concluded that his condition was grave, antecedent, and incurable, rooted in a defective familial background and poor parental molding, which rendered him incapable of fulfilling essential marital obligations.
The Regional Trial Court granted the petition and declared the marriage null and void. However, the Republic, through the Office of the Solicitor General, appealed. The Court of Appeals reversed the RTC decision, finding that the evidence failed to sufficiently prove that Felipe’s alleged psychological incapacity existed at the time of the marriage celebration, met the required gravity, or was truly incurable. Mirasol elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the totality of evidence presented by Mirasol Castillo sufficiently establishes the psychological incapacity of Felipe Impas under Article 36 of the Family Code to warrant a declaration of nullity of their marriage.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court reiterated the stringent guidelines established in Molina and subsequent jurisprudence for declaring a marriage void based on psychological incapacity. The incapacity must be juridically antecedent, existing at the time of the marriage; grave or serious enough to bring about the disability to assume essential marital obligations; and incurable or permanent.
The Court found that Mirasol’s evidence, primarily the psychologist’s report, was insufficient. The report heavily relied on the petitioner’s uncorroborated narration and failed to establish a conclusive link between Felipe’s alleged childhood milieu and his later behavior. Crucially, the evidence did not convincingly demonstrate that his purported personality disorder was already present and incapacitating at the precise moment of marriage in 1984. His infidelity and irresponsibility, which manifested years into the marriage, were more indicative of marital difficulties, not a psychological defect existing at inception. The Court emphasized the state’s interest in preserving marriage and that any doubt must be resolved in favor of its validity. Consequently, the totality of proof failed to meet the exacting standards required for a declaration of nullity under Article 36.