G.R. No. 236279 . March 25, 2019.
Republic of the Philippines, Petitioner, v. Cheryl Pauline R. Deang, Respondent.

FACTS

Cheryl Pauline R. Deang and Emilio Z. Deang were married in 1993. Their cohabitation was brief and tumultuous. Cheryl testified that Emilio quit his job shortly after they lived together, engaged in gambling, and physically abused her during her pregnancy. After the birth of their child, Emilio left for Manila. Cheryl later discovered him in a rented room with another woman. From 1994 onward, they lived separately, with Emilio providing no financial support and reportedly starting a new family. In 2013, Cheryl filed a petition to declare their marriage void under Article 36 of the Family Code, citing Emilio’s psychological incapacity.
During trial, Cheryl presented Dr. Yolanda Lara, a clinical psychologist. Dr. Lara diagnosed Emilio with Anti-Social Personality Disorder based primarily on Cheryl’s narrative and a brief phone conversation with Emilio’s cousin. Dr. Lara admitted her findings on Emilio were not based on a personal examination and relied significantly on Cheryl’s account. The Regional Trial Court declared the marriage void, giving credence to the expert’s report. The Court of Appeals affirmed, holding that the factual narrative itself sufficiently established Emilio’s psychological incapacity.

ISSUE

Whether the Court of Appeals erred in affirming the declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code.

RULING

The Supreme Court granted the petition and reversed the lower courts’ rulings. The marriage remains valid and subsisting. The Court reiterated that psychological incapacity under Article 36 is not a catch-all ground for marital failure but refers to a grave, severe, and incurable psychological condition existing at the time of the marriage that renders a spouse incapable of fulfilling the essential marital obligations. The evidence presented failed to meet this stringent standard.
The Court found the evidence insufficient to prove Emilio’s psychological incapacity. Dr. Lara’s evaluation was fundamentally flawed, as it was not based on a personal examination of Emilio and relied heavily on the uncorroborated statements of the petitioning spouse. The behaviors cited—gambling, abandonment, infidelity, and non-support—while indicative of neglect or irresponsibility, do not per se constitute psychological incapacity as defined by jurisprudence. They were not proven to be manifestations of a grave psychological disorder rooted in Emilio’s history prior to the marriage. The Court emphasized that the State has a compelling interest to protect the institution of marriage, and nullity cannot be decreed based solely on a spouse’s difficult, irresponsible, or even abusive behavior post-marriage without clear evidence of a psychological illness existing at the inception of the marriage that is truly incapacitating.