- Petitioner
- Arthur A. Candelario
- Respondent
- Marlene E. Candelario
- Citation
- G.R. No. 222068
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Hernando, J.
- Decided
- July 25, 2023
Summary
Arthur Candelario petitioned for nullity of his 1984 marriage to Marlene based on psychological incapacity. The RTC denied the petition solely because their marriage predated the Family Code's effectivity. The Supreme Court corrected this ruling, holding that Article 36 applies retroactively to pre-1988 marriages when no vested rights are impaired. However, the SC still denied the petition, finding Arthur failed to prove psychological incapacity under the Tan-Andal doctrine. The psychiatric evidence did not establish the required gravity, incurability, and juridical antecedence of Arthur's alleged Dependent Personality Disorder. Arthur's marital failures appeared to stem from mere refusal or neglect rather than genuine psychological incapacity, insufficient to nullify the marriage under Article 36.