- Petitioner
- Jennifer A. Dedicatoria
- Respondent
- Ferdinand M. Dedicatoria
- Citation
- G.R. No. 250618
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- M.V. Lopez, J.
- Decided
- July 20, 2022
Declaration of nullity of marriage due to psychological incapacity under Article 36 of the Family Code
Summary
The Supreme Court granted Jennifer Dedicatoria's petition to declare her marriage to Ferdinand null and void due to his psychological incapacity. The case clarified that psychological incapacity under Article 36 of the Family Code is a legal, not medical concept, and does not require rigid medical parameters or examination of both spouses. The Court found sufficient evidence through Jennifer's testimony, expert psychological evaluation, and corroborating witnesses to prove Ferdinand's Dependent Personality Disorder rendered him incapable of understanding and fulfilling essential marital obligations. His extreme dependency on his parents, immaturity, and inability to function as a responsible spouse and father were traced to his upbringing and deemed juridically antecedent, grave, and incurable in the legal sense. The decision emphasized that marriage's sanctity requires maintaining only unions that establish genuine conjugal and family life, not condemning spouses to lives of misery due to their partner's psychological dysfunction.