Facts:
Eduardo and Catalina
were married in civil rites. However, the couple were not blessed with a child
because Catalina had a hysterectomy following her second marriage.
Eduardo filed a petition
for declaration of nullity of marriage citing psychological incapacity as a
ground. He alleged that Catalina always left the house without his consent;
that she engaged in petty arguments with him; that she constantly refused to
give in to his sexual needs; that she spent most of her time gossiping with
neighbors instead of caring for their adopted daughter; that she gambled away
all his remittances as an overseas worker; and that she abandoned the conjugal
home with her paramour.
As support to his claim
of psychological incapacity, he also presented the results of a
neuro-psychiatric evaluation conducted by Dr. Annabelle Reyes stating that
Catalina exhibited traits of a borderline personality disorder that was no
longer treatable.
Catalina did not appear
during trial but admitted her psychological incapacity. She denied flirting
with different men and abandoning the conjugal home.
Issue:
Whether or not Catalina
was psychologically incapacitated to fulfill marital duties.
Held:
No. Marriage remains
valid.
Psychological incapacity
is an incapacity/inability to take cognizance of and to assume basic marital
obligations, and is not merely the difficulty, refusal or neglect in the
performance of marital obligations.
In Republic v CA(Molina), the Supreme Court has established guidelines
involving the nullity of marriage based on the ground of psychological
incapacity. These were not met in the instant case since the gravity, root
cause and incurability of Catalina's purported psychological incapacity were
not sufficiently established.
Catalina's behavior of
frequent gossiping, leaving the house without Eduardo's consent, refusal to do
household chores, and take care of their adopted daughter were not established.
Eduardo presented no other witness to corroborate these allegations.
Also, the RTC and CA
heavily relied on Dr. Reyes' evaluation despite any factual foundation to
support this claim. The report was vague about the root cause, gravity and
incurability of the incapacity.Even the testimony of Dr. Reyes stated a general
description of borderline personality disorder which did not explain the root
cause as to why Catalina was diagnosed as such. They did not specify the
acts or omissions or the gravity which constituted the disorder. What was
established was that Catalina was childish and immature.
Furthermore, Dr. Reyes
had only one interview with Catalina. This lacks the depth and objectivity of
an expert assessment.
From the scant evidence
presented, it can be adduced that Catalina's immaturity and apparent refusal to
perform her marital obligations do not constitute psychological incapacity
alone. It must be shown that such immature acts were manifestations of a
disordered personality that made the spouse completely unable to discharge the
essential obligations of marriage.
