G.R. No. 249250. September 29, 2021
JERIK B. ESTELLA, PETITIONER, VS. NIÑA MONRIA AVA M. PEREZ, RESPONDENT, REPUBLIC OF THE PHILIPPINES, OPPOSITOR.

FACTS

Petitioner Jerik B. Estella filed a petition for declaration of nullity of his marriage to respondent Niña Monria Ava M. Perez under Article 36 of the Family Code. He alleged that after their marriage on October 10, 2010, respondent showed signs of psychological incapacity. She was irresponsible, neglectful of their son, prioritized friends over family, frequently left the house after arguments, and stated she did not love him and felt empty and unhappy in the marriage. Clinical psychologist Dr. Maryjun Delgado, based on interviews with petitioner and his cousins, diagnosed respondent with Borderline Personality Disorder and Narcissistic Personality Disorder, characterized by traits such as impulsivity, unstable relationships, lack of empathy, and grandiosity. Dr. Delgado traced this incapacity to respondent’s problematic childhood, marked by parental conflict, her mother’s infidelity, and financial struggles. Respondent denied the allegations, claiming petitioner was irresponsible and overly dependent on his parents. The Regional Trial Court granted the petition, declaring the marriage void ab initio. The Court of Appeals reversed, finding the totality of evidence insufficient to prove psychological incapacity, noting Dr. Delgado’s findings were one-sided as she did not personally examine respondent. Petitioner sought review by the Supreme Court.

ISSUE

Did the Court of Appeals gravely err when it reversed the trial court’s decision declaring the marriage void ab initio on the ground of respondent’s psychological incapacity?

RULING

Yes. The Supreme Court granted the petition, reversed the Court of Appeals, and reinstated the trial court’s decision declaring the marriage void ab initio. Applying the reconfigured concept of psychological incapacity from Tan-Andal v. Andal, the Court held that psychological incapacity is not a medical but a legal concept, referring to personalty causes that result in a party’s failure to understand and perform basic marital obligations. The evidence, including petitioner’s testimony, corroborating witnesses, and the expert opinion of Dr. Delgado, clearly and convincingly established that respondent’s personality disorders, rooted in her dysfunctional childhood, rendered her incapable of fulfilling the essential obligations of marriage—to live together, observe mutual love, respect, fidelity, and render mutual help and support. Her actions demonstrated a persistent refusal or inability to be a caring, faithful, and supportive spouse and mother. The Court found that her incapacity was grave, antecedent, and incurable. The absence of a personal examination of respondent did not invalidate the expert findings, as the totality of evidence presented was sufficient to prove her psychological incapacity.