- Petitioner
- Rahnill Buhian Zamora
- Respondent
- Lourdes Magsalay-Zamora
- Citation
- G.R. No. 253993
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Leonen, J.
- Decided
- October 23, 2023
Whether a marriage should be declared void ab initio due to psychological incapacity of one spouse, and whether a psychological assessment report is…
Summary
This Supreme Court case involved a petition for declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code. The Regional Trial Court dismissed the petition solely because the expert's psychological assessment report was not formally offered in evidence. The Supreme Court reversed, clarifying that such reports are not indispensable requirements and that psychological incapacity can be established through the totality of evidence. The Court emphasized that expert opinion is not always necessary, and ordinary witnesses can testify about observed behaviors. The Court found sufficient evidence of the respondent's Borderline and Narcissistic Personality Disorders, which rendered her incapable of fulfilling essential marital obligations, and declared the marriage void ab initio. This decision liberalized the requirements for nullity petitions and emphasized the primacy of totality of evidence over rigid procedural requirements.
Intellegal Wiki · Key Holding
Granted and marriage declared void ab initio; a psychological assessment report is not indispensable, as psychological incapacity under Article 36 may be proved by the totality of clear and convincing evidence.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.