G.R. No. 246868 . February 15, 2022
REPUBLIC OF THE PHILIPPINES, PETITIONER, VS. ANGELIQUE PEARL O. CLAUR AND MARK A. CLAUR, RESPONDENTS.

FACTS

Angelique Pearl O. Claur filed a petition to declare her marriage to Mark A. Claur void ab initio on the ground of psychological incapacity. The Regional Trial Court granted the petition. The Republic of the Philippines, as oppositor, appealed to the Court of Appeals, which affirmed the trial court’s decision. The Republic then filed this petition for review on certiorari.
Angelique testified that she and Mark had a tumultuous relationship since high school, marked by Mark’s jealousy, philandering, and lies. Their relationship involved frequent break-ups and reconciliations, verbal altercations, and physical violence. They married in January 2009 after Angelique became pregnant, despite her and her parents’ hesitation. After marriage, Mark’s deceit continued (e.g., misrepresenting his academic status and family background), and he was lazy, refused to work, and relied on Angelique for support. Their cohabitation was characterized by quarrels and violence, including an incident where Mark hit Angelique, breaking her jaw. They separated in fact in January 2012.
Johnson C. Tiu, Angelique’s uncle, corroborated her account of the relationship’s instability, Mark’s irresponsibility and infidelity, and the physical abuse.
Dr. Jay Madelon Castillo-Carcereny, a psychiatrist, personally examined Angelique and interviewed her father. She diagnosed Angelique with Borderline Personality Disorder, characterized by frantic efforts to avoid abandonment, unstable relationships, impulsivity, suicidal behavior, affective instability, chronic emptiness, and inappropriate anger. Based on information from Angelique and her father, she diagnosed Mark with Narcissistic Personality Disorder, characterized by grandiosity, preoccupation with fantasies of success, need for admiration, sense of entitlement, interpersonal exploitativeness, lack of empathy, and arrogant behaviors. The doctor traced the root causes to their respective dysfunctional family backgrounds (“double bind” for Mark, “pseudo hostility” for Angelique), which originated in childhood and were deeply entrenched. She concluded these disorders constituted psychological incapacity to comply with essential marital obligations, grave, and incurable.

ISSUE

Whether the Court of Appeals erred in affirming the declaration of nullity of the marriage on the ground of psychological incapacity of both parties.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the Republic’s petition and affirmed the lower courts’ decisions declaring the marriage void ab initio.
The Supreme Court applied the guidelines set forth in Tan-Andal v. Andal. Psychological incapacity is a legal concept that refers to a personal condition that prevents a spouse from fulfilling the essential marital obligations. It must be shown to be: (a) grave, (b) rooted in the history of the person antedating the marriage, (c) incurable, and (d) must pertain to the essential marital obligations of the conjugal community.
The totality of evidence presented met these standards. The factual antecedents detailed the parties’ long history of dysfunctional behavior, including deceit, irresponsibility, violence, and infidelity, which manifested before and during the marriage. The expert psychiatric testimony established that Angelique’s Borderline Personality Disorder and Mark’s Narcissistic Personality Disorder were grave psychological conditions that incapacitated them from understanding and performing their basic marital duties of mutual love, respect, fidelity, and support. These disorders were traced to their childhood family dynamics, proving they were rooted in history and antecedent to the marriage. The doctor’s testimony that the disorders were incurable and that the parties did not perceive their behaviors as problematic was also credited. Therefore, the psychological incapacity of both spouses was sufficiently proven by clear and convincing evidence.