G.R. No. 248675 . July 20, 2022
CLAUDINE MONETTE BALDOVINO-TORRES, PETITIONER, VS. JASPER A. TORRES, RESPONDENT.

FACTS

Petitioner Claudine Monette Baldovino-Torres filed a Petition for Declaration of Nullity of her marriage to respondent Jasper A. Torres under Article 36 of the Family Code. The couple married in 2002 after Claudine became pregnant. Claudine alleged that Jasper was irresponsible, jobless, and dependent on his parents. His behavior included habitual drinking, forced sexual acts, and aggression. He abandoned jobs in Boracay and Dubai shortly after starting them. Claudine eventually left, and Jasper fathered a child with another woman. Claudine presented testimonies from her mother and Clinical Psychologist Dr. Nedy Tayag. Dr. Tayag diagnosed Jasper with Antisocial Personality Disorder, characterized by a pervasive disregard for others, impulsivity, and irresponsibility. She traced the disorder’s roots to his childhood, where excessive maternal leniency and paternal absence fostered his entitled and pleasure-seeking behavior. She concluded his incapacity was grave, rooted in his personality, and incurable.
The Regional Trial Court (RTC) granted the petition, declaring the marriage null and void. The Court of Appeals (CA) reversed the RTC, finding the evidence insufficient. The CA held that Jasper’s behaviors—irresponsibility, immaturity, and refusal to work—did not necessarily constitute psychological incapacity as defined by jurisprudence, emphasizing the lack of proof that these traits existed at the time of the marriage ceremony and were truly incurable.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s finding that Jasper A. Torres was psychologically incapacitated to comply with his essential marital obligations, warranting a declaration of nullity under Article 36 of the Family Code.

RULING

Yes, the Supreme Court reversed the CA and reinstated the RTC’s Decision. The Court clarified that psychological incapacity under Article 36 is a legal concept, not strictly a medical one, and must be proven by the totality of evidence. The guidelines in Molina are not inflexible requirements but aids in adjudication. The Court found that Claudine presented clear and convincing evidence meeting the standard.
The legal logic centered on Jasper’s condition being grave, antecedent, and incurable. His Antisocial Personality Disorder, as established by expert testimony, manifested in a chronic pattern of irresponsibility, lack of initiative, and disregard for marital and parental duties, rendering him incapable of performing the essential obligations of marriage. This incapacity was shown to have juridical antecedence, rooted in his dysfunctional upbringing characterized by excessive maternal indulgence and lack of paternal discipline, which shaped his personality long before the marriage. The incurability was established by the expert’s finding that the disorder was ingrained and resistant to clinical intervention. Jasper’s actions—abandoning jobs, financial dependence, forced sexual relations, and infidelity—were not mere quirks but symptomatic of a severe psychological condition that vitiated his consent to the marital covenant from the outset. Thus, the marriage was declared void ab initio.