G.R. No. 247985 . October 13, 2021
RAPHY VALDEZ DE SILVA, PETITIONER, VS. DONALD DE SILVA AND REPUBLIC OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioner Raphy Valdez De Silva and respondent Donald De Silva were married on June 25, 2005. Shortly after the wedding, respondent used their monetary gifts for gambling and cockfighting. Throughout the marriage, respondent was unemployed, financially dependent on petitioner, and spent money on gambling, drinking, and extramarital affairs. He subjected petitioner to physical and verbal abuse, including threats with a knife and punches, and threatened to burn her mother’s house. In 2008, respondent incurred loans without petitioner’s knowledge, forcing her to sell her jewelry to pay the debts. Due to the stress and abuse, petitioner was confined in a therapeutic hospital in 2011. In April 2012, petitioner left the conjugal home after receiving further threats via text message. She and her mother secured a Barangay Protection Order. Petitioner filed a Petition for declaration of nullity of marriage under Article 36 of the Family Code. Clinical psychologist Dr. Nedy L. Tayag evaluated the parties and diagnosed respondent with Anti-Social Personality Disorder, characterized by a pervasive disregard for the rights of others, deceitfulness, impulsivity, irritability, aggressiveness, reckless disregard for safety, consistent irresponsibility, and lack of remorse. The report traced this condition to his dysfunctional family background. The Regional Trial Court declared the marriage void ab initio. The Court of Appeals reversed, finding the psychological report insufficient to prove respondent’s psychological incapacity.

ISSUE

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

RULING

Yes. The Supreme Court granted the Petition, reversed the Court of Appeals’ Decision and Resolution, and reinstated the Regional Trial Court’s Decision declaring the marriage void ab initio. Applying the guidelines in Tan-Andal v. Andal, the Court found that respondent’s psychological incapacity was sufficiently proven. The evidence established that his Anti-Social Personality Disorder was grave, rooted in his history, and incurable. His pattern of behavior—financial irresponsibility, gambling, infidelity, violence, threats, and lack of remorse—manifested a utter insensitivity or inability to give meaning and significance to the marriage. This incapacity existed at the time of the marriage celebration, was medically or clinically identified, and shown to be permanent. The psychological report, corroborated by petitioner’s testimony and other evidence, clearly demonstrated that respondent was incapable of performing the basic marital obligations of cohabitation, mutual support, and fidelity.