G.R. No. 222908 , December 06, 2021
PATRICIA Q. AUSTRIA-CARREON, PETITIONER, VS. LUIS EMMANUEL G. CARREON AND REPUBLIC OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioner Patricia Q. Austria-Carreon filed a Petition for Declaration of Absolute Nullity of Marriage against respondent Luis Emmanuel G. Carreon under Article 36 of the Family Code, alleging mutual psychological incapacity. The parties married in 1994 after petitioner became pregnant. During cohabitation, respondent failed to provide voluntary financial support, was emotionally distant, and had extramarital affairs, leading to a separation in 2000. A brief reconciliation in 2001 failed due to lingering issues and a later discovery of another infidelity in 2007. Petitioner presented a Psychological Evaluation Report by Dr. Julian R. Montano, who diagnosed petitioner with “Personality Disorder Not Otherwise Specified” demonstrative of Dependent and Depressive Personality Disorders, and respondent with Narcissistic Personality Disorder. Dr. Montano opined these disorders were grave, incurable, and rendered them incapable of fulfilling essential marital obligations. The Regional Trial Court (RTC) declared the marriage null and void. The Republic, through the OSG, appealed. The Court of Appeals (CA) reversed the RTC, finding no evidence that the alleged psychological incapacity was serious, incurable, and rooted in medical causes, dismissing the petition. Petitioner elevated the case via a Petition for Review and Original Action for Certiorari under Rules 45 and 65.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s declaration of nullity of marriage, specifically in finding that the psychological incapacity of the parties was not sufficiently proven to be grave, serious, incurable, and rooted in medical causes as required by Article 36 of the Family Code and jurisprudence.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. The Court held that the totality of evidence failed to prove that the parties’ psychological incapacity was grave, serious, incurable, and rooted in medical causes. The Court applied the guidelines from Republic v. Molina and the more recent doctrine in Tan-Andal v. Andal, which emphasizes that the incapacity must be medically or clinically identified, incapacitating, and existing at the time of the marriage celebration. The Court found that the behaviors described—respondent’s lack of financial support, emotional detachment, infidelity, and petitioner’s dependency and pessimism—were not shown to be manifestations of a psychological disorder that was grave and incurable. The expert’s diagnosis of “Personality Disorder Not Otherwise Specified” was deemed insufficient, as it was not clearly linked to a medically rooted incapacity that existed at the inception of the marriage. The Court concluded that the alleged dysfunctions amounted to mere difficulty, refusal, or neglect in the performance of marital obligations, not the psychological incapacity contemplated by Article 36. Thus, the marriage remained valid and subsisting.