GR 253342; (May, 2022) (Digest)
G.R. No. 253342 . June 22, 2022.
DIONISIO C. LAROCO, PETITIONER, VS. AURORA B. LAROCO AND REPUBLIC OF THE PHILIPPINES, RESPONDENTS.
FACTS
Petitioner Dionisio C. Laroco filed a petition for declaration of nullity of his marriage to respondent Aurora B. Laroco based on psychological incapacity under Article 36 of the Family Code. He alleged that their marriage in 1971 was forced upon him by respondent’s parents after she informed him she was pregnant. During the marriage, respondent was promiscuous, dishonest, and flirtatious, going on dates with other men and incurring debts without his knowledge. She was arrested for estafa. After her release on bail, she left their home, took their children, and lived with a paramour. The children later chose to live with petitioner. Petitioner presented a psychiatrist, Dr. Clarette Rosario Dy, who diagnosed him with Obsessive-Compulsive Personality Disorder and respondent with Histrionic Personality Disorder. Dr. Dy opined that these disorders existed at the time of the marriage, were grave, incurable, and rendered them psychologically incapacitated to assume essential marital obligations. The Regional Trial Court denied the petition, finding the totality of evidence insufficient to prove psychological incapacity that was grave, incurable, and antecedent. The Court of Appeals affirmed the RTC decision.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s denial of the petition for declaration of nullity of marriage on the ground of psychological incapacity.
RULING
No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the assailed Court of Appeals decision. The Court, applying the guidelines in Tan-Andal v. Andal, held that the evidence failed to prove that the parties’ personality disorders constituted psychological incapacity within the meaning of Article 36. The expert’s conclusions were primarily based on petitioner’s self-serving narrations and failed to establish a conclusive link between the diagnosed disorders and a true incapacity to understand and fulfill the basic marital obligations, as opposed to a mere refusal or difficulty. The disorders’ gravity and incurability were not sufficiently proven. The totality of evidence did not show that these conditions were so severe and pervasive that they completely deprived the parties of the ability to assume the essential obligations of marriage from the beginning.