- Petitioner
- Republic
- Respondent
- Crasus L. Iyoy
- Citation
- G.R. No. 152577
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Chico-Nazario, J.
- Decided
- September 21, 2005
Summary
The Supreme Court reversed lower court decisions that declared null and void the 1961 marriage between Crasus Iyoy and Fely Rosal-Iyoy. Crasus sought nullity based on his wife's alleged psychological incapacity after she abandoned the family in 1984, obtained divorce abroad, and remarried an American citizen. The RTC and Court of Appeals granted the petition, but the Supreme Court found insufficient evidence to establish the grave, incurable psychological incapacity required under Article 36 of the Family Code. The Court emphasized that abandonment, infidelity, and difficult behavior, while problematic, do not constitute the serious mental illness necessary for nullity. The Court also ruled that Article 26 of the Family Code was inapplicable since Fely was still Filipino when she divorced. The decision reinforced constitutional protection of marriage validity and the principle that doubts should favor marriage continuation over dissolution.
Intellegal Wiki · Key Holding
Abandonment, sexual infidelity, and similar marital wrongs, however hurtful, do not by themselves constitute psychological incapacity; any doubt is resolved in favor of the validity of the marriage.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.