G.R. No. 217993 , August 9, 2017
Manuel R. Bakunawa III, Petitioner, vs. Nora Reyes Bakunawa, Respondent.

FACTS

Petitioner Manuel R. Bakunawa III and respondent Nora Reyes Bakunawa were married in 1975. Their relationship deteriorated due to Manuel’s frequent absences for work, extramarital affairs, and failure to provide for the family, alongside Nora’s alleged passivity and neglect of household duties. The couple separated in 1980, with Manuel cohabiting with another woman. In 2008, Manuel filed a petition for declaration of nullity of marriage under Article 36 of the Family Code, alleging mutual psychological incapacity. He presented psychiatrist Dr. Cecilia Villegas, who diagnosed him with Intermittent Explosive Disorder and Nora with Passive Aggressive Personality Disorder. These diagnoses were based solely on interviews with Manuel and their eldest son, as Nora did not participate in the evaluation. The Regional Trial Court granted the petition, declaring the marriage null and void.

ISSUE

Whether the totality of evidence presented is sufficient to prove the parties’ psychological incapacity to comply with the essential marital obligations, warranting a declaration of nullity under Article 36 of the Family Code.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ ruling upholding the validity of the marriage. The Court held that the evidence was insufficient to establish psychological incapacity as defined by Article 36 and jurisprudence. The psychiatric evaluation and testimony of Dr. Villegas lacked probative value because her diagnoses were derived exclusively from interviews with Manuel and one child, without Nora’s participation or corroborative evidence from other intimate witnesses. The Court emphasized that while expert testimony is not always indispensable, the totality of evidence must convincingly demonstrate a grave, severe, and incurable psychological condition existing at the time of the marriage. Here, the evidence merely illustrated marital strife, incompatibility, and irresponsible behavior—not the required juridical antecedence, gravity, and incurability. The Court also noted the absence of objective psychometric tests to substantiate the alleged disorders. Furthermore, a confirmatory decree from an ecclesiastical tribunal was accorded respect but was not considered controlling. Consequently, the petition failed to meet the stringent evidentiary standard for nullity, and the marriage remains valid.