Whether respondent's alleged psychological incapacity warrants declaration of nullity of marriage under Article 36 of the Family Code
Summary
Wife sought nullity of marriage based on husband's alleged psychological incapacity manifested through domestic violence, habitual drinking, and irresponsible behavior starting in 1988. The RTC granted the nullity, but the Court of Appeals reversed, finding insufficient evidence of psychological incapacity as defined by law. The Supreme Court affirmed the CA decision, holding that emotional immaturity and irresponsibility do not constitute psychological incapacity under Family Code Article 36. The Court applied the Santos and Molina doctrines requiring psychological incapacity to be a mental condition causing true incognizance of basic marital covenants, limited to the most serious personality disorders. The marriage was declared valid and subsisting, emphasizing that marriage is an inviolable social institution protected by the State.
Focus of dispute
Whether respondent's alleged psychological incapacity warrants declaration of nullity of marriage under Article 36 of the Family Code
Legal facts
Petitioner Lorna and respondent Zosimo married on March 3, 1975 after meeting on an inter-island vessel. They had four children. Starting in 1988, respondent allegedly showed psychological incapacity through emotional immaturity, irresponsibility, habitual drinking, and domestic violence. On March 22, 1994, respondent assaulted petitioner, causing injuries requiring medical attention. He was convicted of slight physical injuries. Petitioner and children left the conjugal home and petitioner filed for declaration of nullity based on psychological incapacity.
Judgement and reasoning
{"Court of Appeals (CA)": "Reversed RTC decision and declared marriage valid and subsisting. Found that petitioner failed to establish: (1) mental incapacity causing true incognizance of basic marital covenant; (2) that incapacity is grave, preceded marriage and is incurable; (3) that incapacity is psychological not physical; (4) that root cause was medically/clinically identified and proven by expert; (5) that incapacity is permanent and incurable.", "Regional Trial Court (RTC) of Caloocan City, Branch 130": "Declared the marriage null and void ab initio based on psychological incapacity of respondent and ordered liquidation of conjugal partnership.", "Supreme Court (SC)": "Affirmed CA decision and denied petition. Applied Santos and Molina doctrines defining psychological incapacity as mental incapacity causing true incognizance of basic marital covenants, limited to most serious personality disorders. Found that emotional immaturity and irresponsibility cannot be equated with psychological incapacity. Emphasized marriage as inviolable social institution that State protects."}