Santos v. Court of Appeals

Summary

This landmark Supreme Court case addressed the interpretation of Article 36 of the Family Code regarding psychological incapacity as grounds for nullity of marriage. Leouel Santos sought to nullify his marriage to Julia Rosario Bedia-Santos, claiming her five-year absence and lack of communication constituted psychological incapacity to fulfill essential marital obligations. The Court denied the petition, establishing important jurisprudential guidelines that psychological incapacity must involve serious personality disorders demonstrating utter insensitivity or inability to understand marriage's significance, not mere abandonment or communication failures. The decision emphasized marriage as an inviolable social institution requiring the most stringent standards for nullity declarations, providing extensive analysis of the Family Code's legislative history and canonical law origins to guide future interpretations of Article 36.