Whether respondent Benjamin L. Singson has psychological incapacity under Article 36 of the Family Code to nullify the marriage due to alleged…
Summary
This case involves a petition for declaration of nullity of marriage filed by Maria Concepcion Singson against her husband Benjamin Singson based on Article 36 of the Family Code, claiming he suffered from psychological incapacity due to pathological gambling and personality disorder. The Regional Trial Court initially granted the petition, finding that respondent's psychological incapacity was grave, incurable, and had juridical antecedence. However, the Court of Appeals reversed this decision, and the Supreme Court affirmed the reversal. The higher courts found that petitioner failed to prove that respondent's alleged psychological incapacity met the required legal standards of being grave, serious, incurable, and existing at the time of marriage. The Supreme Court emphasized that respondent demonstrated capability to perform marital duties through his employment, financial support to the family, and continued cohabitation. The case reinforces the constitutional protection of marriage as an inviolable social institution and the stringent requirements for proving psychological incapacity under Article 36 of the Family Code.
Focus of dispute
Whether respondent Benjamin L. Singson has psychological incapacity under Article 36 of the Family Code to nullify the marriage due to alleged pathological gambling and personality disorder
Legal facts
Maria Concepcion and Benjamin Singson were married on July 6, 1974 at St. Francis Church, Mandaluyong, Rizal, producing four children. Petitioner alleged respondent suffered from pathological gambling, personality disorder, dishonesty, extravagance, immaturity, irresponsibility, and infidelity. Respondent was confined at Metro Psych Facility for treatment. Dr. Benita Sta. Ana-Ponio diagnosed respondent with pathological gambling and personality disorder. Petitioner claimed these conditions made respondent psychologically incapacitated to perform essential marital obligations and that these conditions existed before marriage, were grave, and incurable.
Judgement and reasoning
{"Court of Appeals (CA)": "Reversed and set aside the RTC decision, dismissing the petition. Held that totality of evidence failed to establish respondent's psychological incapacity as grave, serious, incurable, or existing at time of marriage. Found that respondent was capable of carrying out ordinary duties of married man as evidenced by his employment, providing family support, and living with family. Ruled that pathological gambling arose after marriage and that mere difficulty in performance of marital obligations differs from incapacity rooted in debilitating psychological condition.", "Regional Trial Court (RTC)": "Granted the petition and declared the marriage void ab initio on ground of respondent's psychological incapacity. Found that respondent suffered from Personality Disorder known as Pathological Gambling that was grave, incurable, and had juridical antecedence. Ruled that this psychological disorder hindered performance of marital obligations as husband and father, and that the disorder was present at time of marriage but became manifest later.", "Supreme Court (SC)": "Denied the petition and affirmed the Court of Appeals decision. Held that petitioner failed to prove psychological incapacity was grave, serious, and incurable as required by jurisprudential parameters. Found that respondent demonstrated capability to perform marital duties through employment, providing family support, accompanying wife during childbirth, and living with family. Ruled that evidence did not establish juridical antecedence of the alleged incapacity, and that psychiatric evaluation was insufficient and based partly on hearsay. Emphasized constitutional policy protecting marriage as inviolable social institution."}