G.R. No. 231695 . October 06, 2021
MA. VIRGINIA D.R. HALOG, PETITIONER, VS. WILBUR FRANCIS G. HALOG AND THE REPUBLIC OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioner Ma. Virginia D.R. Halog sought the declaration of nullity of her marriage to respondent Wilbur Francis G. Halog on the ground of psychological incapacity under Article 36 of the Family Code. She testified that before their marriage in 1993, she discovered Wilbur was having an affair but proceeded with the wedding. During the marriage, Wilbur was abusive, temperamental, unfaithful, and neglectful of his family. He aimed a gun at her during an argument, engaged in multiple extra-marital affairs, stopped providing financial support, and eventually married another woman in Qatar in 2006. Petitioner’s brother and a friend corroborated her accounts of abuse and infidelity. Dr. Melchor C. Gomintong, a psychiatrist, examined petitioner and diagnosed her with Avoidant Personality Disorder. He attempted but failed to examine Wilbur; instead, he conducted collateral interviews with petitioner’s brother and friend and diagnosed Wilbur with Anti-Social Personality Disorder, concluding both were psychologically incapacitated. The Regional Trial Court granted the petition, finding Wilbur psychologically incapacitated but not petitioner. The Republic, through the Office of the Solicitor General (OSG), appealed to the Court of Appeals, which reversed the RTC decision. The CA held that the evidence failed to prove Wilbur’s psychological incapacity in accordance with the guidelines in Republic v. Molina, noting that Dr. Gomintong’s findings on Wilbur were speculative, based on hearsay, and failed to establish the root cause, gravity, and incurability of his alleged disorder. Petitioner’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s decision and in ruling that petitioner failed to prove respondent’s psychological incapacity to comply with essential marital obligations.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The Court held that petitioner failed to prove respondent’s psychological incapacity by clear and convincing evidence. Applying the guidelines in Republic v. Molina and the more recent case of Tan-Andal v. Andal, the Court found the evidence insufficient. Dr. Gomintong’s diagnosis of Wilbur was based solely on collateral interviews, not a personal examination, and the information provided by petitioner and her witnesses, while detailed, pertained to Wilbur’s problematic behavior during the marriage (infidelity, abuse, neglect) but did not conclusively establish that these actions stemmed from a psychological disorder that was grave, juridically antecedent, and incurable. The expert’s report failed to adequately explain the root cause of Wilbur’s alleged Anti-Social Personality Disorder and to medically link his behavior to a psychological illness existing at the time of the marriage. The Court emphasized that mere difficulty, refusal, or neglect in performing marital obligations, or marital infidelity, does not necessarily constitute psychological incapacity. The totality of evidence did not meet the required standard of proof. Thus, the marriage between petitioner and respondent remains valid and subsisting.