Civil Law

Te v. Te G.R. No. 161793 February 13, 2009 Psychological Incapacity

FACTS:

Petitioner Edward and respondent Rowena met and became sweethearts while they were in college . Around three months after their first meeting, Rowena asked Edward to elope. Petitioner provided their travel money and Rowena purchased the boat ticket to Cebu. Their money  eventually ran out and they decided to go back to Manila. Rowena stayed with her uncle’s house and Edward went to his parents’ home. Edward later agreed to stay with Rowena at her uncle’s place after she threatened to commit suicide.

On April 23, 1996, Rowena’s uncle brought the two to a court to get married.

The two then continued to stay at her uncle’s place where Edward was not allowed to go out unaccompanied. Her uncle also showed Edward his guns and warned him not to leave Rowena. Rowena suggested that Edward should get his inheritance so that they could live on their own.

Edward escaped from the house of Rowena’s uncle and stayed with his parents. His family then hid him from Rowena and her family.

In June 1996, they parted ways. After almost four years, or on January 18, 2000, Edward filed a petition for the annulment of his marriage to Rowena on the basis of the latter’s psychological incapacity.

The trial court declared the marriage of the parties null and void on the ground that both parties were psychologically incapacitated to comply with the essential marital obligations.

The CA reversed and set aside the trial court’s ruling.

Dissatisfied, petitioner filed before this Court the instant petition for review on certiorari.

 

ISSUE:

Whether or not, based on Article 36 of the Family Code, the marriage between the parties is null and void.

 

RULING:

Article 36 of the Family Code provides:

Article 36. 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.

As held in Santos, the phrase psychological incapacity is not meant to comprehend all possible cases of psychoses. It refers to no less than a mental (not physical) incapacity that causes a party to be truly noncognitive of the basic marital covenants that concomitantly must be assumed and discharged by the parties to the marriage which, as expressed by Article 68 of the Family Code, include their mutual obligations to live together, observe love, respect and fidelity; and render help and support. The intendment of the law has been to confine it to the most serious of cases of personality disorders clearly demonstrative of an utter insensitivity or inability to give meaning and significance to the marriage.

The psychologist who provided expert testimony found both parties psychologically incapacitated. Petitioners behavioral pattern falls under the classification of dependent personality disorder, and respondents, that of the narcissistic and antisocial personality disorder.

By the very nature of Article 36, courts, despite having the primary task and burden of decision-making, must not discount but, instead, must consider as decisive evidence the expert opinion on the psychological and mental temperaments of the parties.

In dissolving marital bonds on account of either party’s psychological incapacity, the Court is not demolishing the foundation of families, but it is actually protecting the sanctity of marriage, because it refuses to allow a person afflicted with a psychological disorder, who cannot comply with or assume the essential marital obligations, from remaining in that sacred bond.

In the case at bench, the psychological assessment, which we consider as adequate, produced the findings that both parties are afflicted with personality disorders, dependent personality disorder for petitioner, and narcissistic and antisocial personality disorder for respondent.

The seriousness of the diagnosis and the gravity of the disorders considered, the Court, in this case, finds as decisive the psychological evaluation made by the expert witness; and, thus, rules that the marriage of the parties is null and void on ground of both parties psychological incapacity.

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