G.R. No. 248518 . December 07, 2021.
JANICE MARISTELA-CUAN, PETITIONER, VS. MARCELINO A. CUAN, JR., AND THE REPUBLIC OF THE PHILIPPINES, RESPONDENTS.

FACTS

Petitioner Janice Maristela-Cuan sought the declaration of nullity of her marriage to respondent Marcelino A. Cuan, Jr. on the ground of psychological incapacity under Article 36 of the Family Code. They were married on June 20, 1997. Janice testified that after the wedding, they never lived together, only meeting after work and on weekends. They attempted to have sex about five times in motels, but Marcelino would always stop. Marcelino exhibited extreme, violent jealousy, prohibiting her from talking to other men and physically hurting her. Their last communication was in 1999 after an argument. Janette Velasco, a friend, corroborated that the couple never cohabited and that Marcelino was unfoundedly jealous. Clinical Psychologist Dr. Nedy L. Tayag diagnosed Janice with Passive-Aggressive Personality Disorder, rooted in her need for attachment. Despite Marcelino’s non-appearance for examination, Dr. Tayag diagnosed him with Paranoid Personality Disorder with Narcissistic and Antisocial Features, based on a psychodynamic analysis of his reported behavior, attributing it to his upbringing in a broken family. She concluded both disorders were grave, chronic, incurable, and juridically antecedent. The Regional Trial Court granted the petition, declaring the marriage void. The Court of Appeals reversed, finding the evidence insufficient to prove psychological incapacity, ruling that the described behaviors indicated immaturity, not a psychological illness, and that the expert’s analysis lacked depth on the required severity, antecedence, and incurability.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s decision and in holding that the totality of evidence presented was insufficient to prove that both parties were psychologically incapacitated to comply with the essential marital obligations at the time of the marriage celebration.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. The totality of evidence failed to prove that the parties’ psychological conditions, assuming they existed, constituted psychological incapacity as defined by Article 36 of the Family Code and jurisprudence. The evidence did not convincingly establish that their alleged disorders were grave, serious, incurable, and existing at the time of the marriage celebration (juridical antecedence). Janice’s own testimony showed she entered the marriage voluntarily and understood its obligations, and her actions (e.g., attempting to contact Marcelino after a fight) demonstrated an effort to fulfill her duties, contradicting a finding of incapacity. The expert’s diagnosis of Marcelino, rendered without personal examination and based solely on the petitioner’s accounts, was insufficient and unreliable to prove his psychological state at the time of the marriage. His described behavior—jealousy, violence, refusal to cohabit—suggested neglect, refusal, or difficulty, but not an incurable psychological disorder rooted in his personality. The parties’ failure to cohabit, by itself, is not proof of psychological incapacity but may be due to other reasons. The marriage bond remains valid.