Petitioner filed with the Regional Trial Court a petition for nullity of marriage on the grounds of psychological incapacity of both parties. She averred that respondent had been medically ascertained as suffering from “inadequate personality disorder related to masculine strivings associated with unresolved oedipal complex” while she was diagnosed with “personality disorder of the mixed type, histrionic, narcissistic with immaturity”.
Medical experts Dr. Villegas and Dr. Encarnacion attested to the alleged psychological incapacities of both parties with the latter remarking that there was “no chance of a successful marriage in a dysfunctional union when there is double psychological incapacity”.
The Regional Trial Court denied the petition. Meanwhile, the Court of Appeals affirmed the lower court’s decision and added that the medical experts failed to paint a clear picture of supposed gravity or seriousness of respondent’s psychological incapacity. It ruled that irreconcilable differences, not psychological incapacity, marred their marriage.
Issue:
Whether or not the psychological conditions of the parties fall under Article 36 of the Family Code to warrant the declaration of nullity of marriage
Ruling:
The petition was denied.
Article 36 of the Family Code provides that “A marriage contracted by any party, who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization.”
The Court upheld the doctrine in Santos v. CA which stated that psychological incapacity must be characterized by (a) gravity, (b) juridical antecedence, and (c) incurability. In addition, the burden of proof to show nullity of marriage lies with the plaintiff. Here, the petitioner failed to substantiate respondent’s penchant for womanizing as a manifestation of his psychological incapacity and failed to present irrefutable proof to corroborate her claims of his sexual proclivities.
According to Justice Del Castillo, a marriage, even if unsatisfactory, is not a null and void marriage.
