Civil Law

Viñas v. Viñas G.R. No. 208790, January 21, 2015 Psychological Incapacity

FACTS:

On April 26, 1999, Glenn and Mary Grace got married in civil rites held in Lipa City, Batangas. Mary Grace was already pregnant then. The infant, however, died at birth due to weakness and malnourishment. 

The couple lived together under one roof. Glenn worked as a bartender, while Mary Grace was a production engineer.

Glenn filed a Petition for the declaration of nullity of his marriage with Mary Grace. He alleged that Mary Grace was insecure, extremely jealous, outgoing and prone to regularly resorting to any pretext to be able to leave the house; that she thoroughly enjoyed the night life, and drank and smoked heavily even when she was pregnant; that she refused to perform even the most essential household chores of cleaning and cooking; that Mary Grace was not remorseful about the death of the infant whom she delivered; that. she lived as if she were single and was unmindful of her husband’s needs; that she was self-centered, selfish and immature; that when Glenn confronted her about her behavior, she showed indifference.; that she eventually left their home without informing Glenn; that Glenn later found out that she left for an overseas employment in Dubai.

Glenn sought professional guidance and submitted himself to a psychological evaluation by Clinical Psychologist Nedy Tayag. Dr. Tayag found him as “amply aware of his marital roles” and “capable of maintaining a mature and healthy heterosexual relationship.”

On the other hand, Dr. Tayag assessed Mary Grace’s personality through the data she had gathered from Glenn and his cousin, Rodelito Mayo, who knew Mary Graceway back in college.

Dr. Tayag diagnosed Mary Grace to be suffering from a Narcissistic Personality Disorder with anti-social traits. Dr. Tayag concluded that Mary Grace and Glenn’s relationship is not founded on mutual love, trust, respect, commitment and fidelity to each other. Hence, Dr. Tayag recommended the propriety of declaring the nullity of the couple’s marriage.

The RTC rendered its Decision declaring the marriage between Glenn and Mary Grace as null and void on account of the latter’s psychological incapacity.

On appeal, the CA rendered the herein assailed decision reversing the RTC ruling and declaring the marriage between Glenn and Mary Grace as valid and subsisting.

The CA, through the herein assailed Resolution, denied the Motion for Reconsideration filed by Glenn.

ISSUE:

Whether or not the totality of the evidence presented by [Glenn] warrants the grant of the petition.

RULING:

The lack of personal examination or assessment of the respondent by a psychologist or psychiatrist is not necessarily fatal in a petition for the declaration of nullity of marriage. “If the totality of evidence presented is enough to sustain a finding of psychological incapacity, then actual medical examination of the person concerned need not be resorted to.”

In the instant petition, however, the cumulative testimonies of Glenn, Dr. Tayag and Rodelito, and the documentary evidence offered do not sufficiently prove the root cause, gravity and incurability of Mary Grace’s condition. The evidence merely shows that Mary Grace is outgoing, strong-willed and not inclined to perform household chores. 

While Glenn and Mary Grace possess incompatible personalities, the latter’s acts and traits do not necessarily indicate psychological incapacity. 

To use the words of Navales v. Navales:

Article 36 contemplates downright incapacity or inability to take cognizance of and to assume basic marital obligations. Mere “difficulty,” “refusal” or “neglect” in the performance of marital obligations or “ill will” on the part of the spouse is different from “incapacity” rooted on some debilitating psychological condition or illness. Indeed, irreconcilable differences, sexual infidelity or perversion, emotional immaturity and irresponsibility, and the like, do not by themselves warrant a finding of psychological incapacity under Article 36, as the same may only be due to a person’s refusal or unwillingness to assume the essential obligations of marriage and not due to some psychological illness that is contemplated by said rule.

Mary Grace’s departure from their home in 2006 indicates either a refusal or mere difficulty, but not absolute inability to comply with her obligation to live with her husband.

Further, considering that Mary Grace was not personally examined by Dr. Tayag, there arose a greater burden to present more convincing evidence to prove the gravity, juridical antecedence and incurability of the former’s condition. Glenn, however, failed in this respect.

While the Court also commiserates with Glenn’s marital woes, the totality of the evidence presented provides inadequate basis for the Court to conclude that Mary Grace is indeed psychologically incapacitated to comply with her obligations as Glenn’s spouse.

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