G.R. No. 240802. September 29, 2021
Rena Montealto-Laylo, Petitioner, vs. Thomas Johnson S. Ymbang and Republic of the Philippines, Respondents.

FACTS

Petitioner Rena Montealto-Laylo and respondent Thomas Johnson S. Ymbang were married on December 23, 2010, in Dubai. Shortly after, Thomas returned to the Philippines due to health issues. Rena filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code, alleging psychological incapacity on both their parts. She submitted a Psychiatric Report by Dr. Romeo Z. Roque, who diagnosed her with Borderline Personality Disorder, characterized by an insatiable craving for attention, extreme jealousy, threats of self-harm, distrust, and loneliness. Thomas was diagnosed with Dependent Personality Disorder, manifesting as indecisiveness and over-attachment to his sibling. Rena also presented her judicial affidavit and that of her sister-in-law. Thomas did not file any responsive pleading. The Regional Trial Court (RTC) granted the petition, declaring the marriage null and void. The Office of the Solicitor General (OSG) appealed. The Court of Appeals (CA) reversed the RTC, dismissing the petition, finding that the evidence failed to establish psychological incapacity as the behaviors shown constituted mere refusal, not incapacity, to perform marital obligations, and that the expert report failed to explain the incurability of the conditions.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s decision and dismissing the petition for declaration of nullity of marriage on the ground of psychological incapacity.

RULING

Yes, the Supreme Court granted the Petition for Review on Certiorari, reversing the CA and reinstating the RTC’s decision. The Court applied the restated guidelines from the En Banc case of Tan-Andal v. Andal, which reformulated the restrictive Republic v. Molina guidelines. The Court found that the totality of evidence, including Dr. Roque’s expert report and the testimonies of ordinary witnesses, clearly and convincingly established the psychological incapacity of both parties. Rena’s Borderline Personality Disorder and Thomas’s Dependent Personality Disorder were medically identified, existed at the time of the marriage, were grave, incurable, and rendered them incapable of fulfilling their essential marital obligations. The expert opinion, corroborated by other evidence, sufficiently showed the root cause, juridical antecedence, gravity, and incurability of their psychological conditions. The dysfunctional acts, such as Rena’s extreme jealousy and self-harm threats and Thomas’s indecisiveness and clinging dependence, undermined the marriage. Therefore, the marriage was declared null and void under Article 36 of the Family Code.