G.R. No. 226907, July 22, 2019
Gerardo A. Eliscupidez, Petitioner, vs. Glenda C. Eliscupidez, Respondent.

FACTS

Petitioner Gerardo filed a Petition for Declaration of Nullity of Marriage against respondent Glenda on the ground of her psychological incapacity under Article 36 of the Family Code. He alleged that during their marriage, Glenda exhibited abusive, violent, and irresponsible behavior. This included frequent quarrels where she would throw objects, attempts to procure abortifacients, extreme jealousy leading to restrictions on his social and work life, financial irresponsibility, neglect of their children, and engagement in extramarital affairs, from which she bore children with another man. To support his petition, Gerardo presented the testimony of their former househelper and a Psychological Evaluation Report by Dr. Nedy Tayag. The report diagnosed Glenda with Histrionic Personality Disorder with Anti-Social Traits, concluding she was psychologically incapacitated to fulfill her marital obligations. The Regional Trial Court granted the petition and declared the marriage void.
The Court of Appeals reversed the RTC decision. It found the evidence insufficient to prove psychological incapacity, noting that the psychologist’s evaluation of Glenda was based solely on interviews with Gerardo and other witnesses, not on a personal examination of Glenda herself. The CA ruled that the behaviors described, while indicative of marital strife, did not conclusively establish a grave, severe, and incurable psychological condition existing at the time of the marriage’s celebration. Gerardo elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in reversing the RTC and in ruling that the evidence presented was insufficient to prove respondent’s psychological incapacity to nullify the marriage under Article 36 of the Family Code.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic centers on the stringent requirements for nullity based on psychological incapacity as established in Santos v. CA and Molina. The Court reiterated that the incapacity must be grave, rooted in the party’s psyche prior to the marriage, and incurable. It must consist of a true inability to understand and perform the essential marital obligations, not merely a refusal, difficulty, or neglect.
The Court found that the totality of evidence failed to meet this standard. While the psychologist’s report diagnosed a personality disorder, the assessment of respondent was not based on a personal clinical examination but on hearsay accounts from petitioner and other witnesses. The cited behaviors—jealousy, quarrels, infidelity, and irresponsibility—though regrettable, were deemed manifestations of marital conflict, not definitive proof of a psychological defect so severe as to constitute incapacity at the time of the wedding. The Court emphasized that Article 36 is not a remedy for failed marriages but a limited ground for nullity requiring clear and convincing evidence of a psychological illness existing at inception. The petitioner’s evidence fell short of proving that respondent’s condition was truly permanent and incurable, and juridically antecedent. Consequently, the marriage stands.