G.R. No. 230443 . April 3, 2019. MARY CHRISTINE C. GO-YU, Petitioner, vs. ROMEO A. YU, Respondent.
FACTS

Petitioner Mary Christine C. Go-Yu filed a Petition for Declaration of Nullity of Marriage against respondent Romeo A. Yu, alleging her psychological incapacity under Article 36 of the Family Code. She claimed to be suffering from Narcissistic Personality Disorder (NPD), which existed prior to the marriage and rendered her incapable of fulfilling her essential marital obligations. She presented testimonial and documentary evidence, including a psychiatrist’s report, detailing her self-assured and independent personality, difficulties in marital adjustment, lack of sexual intimacy, and her perception that her behavior required no change. After petitioner rested her case, respondent filed a Demurrer to Evidence, arguing petitioner failed to prove psychological incapacity by clear and convincing evidence. The Regional Trial Court denied the demurrer, finding petitioner had presented substantial evidence warranting respondent’s presentation of controverting evidence.

ISSUE

Whether the Court of Appeals correctly granted the respondent’s Demurrer to Evidence and dismissed the petition for declaration of nullity of marriage.

RULING

Yes, the Supreme Court affirmed the Court of Appeals’ decision. The grant of a demurrer to evidence is proper when the plaintiff’s evidence is insufficient to justify a judgment in their favor. In nullity cases, the burden is on the petitioner to prove psychological incapacity by clear and convincing evidence, showing a grave, severe, and incurable psychological condition existing at the time of the marriage. The Court found petitioner’s evidence sorely lacking. The psychiatrist’s report and testimonies merely described petitioner’s personality traits—self-assurance, independence, and difficulty adjusting to married life—but failed to establish a natal or supervening psychological disorder that was truly incapacitating. The evidence did not demonstrate that these traits were so severe as to constitute a juridical antecedent that completely deprived her of the ability to understand and perform her marital duties. At best, the evidence pointed to refusal, neglect, or difficulty in compliance, which is insufficient under Article 36. The trial court thus gravely abused its discretion in denying the demurrer, as requiring the respondent to present evidence against an inherently weak case would have been a waste of time and resources. Consequently, the petition for nullity was correctly dismissed.