- Petitioner
- Bandilla
- Respondent
- Obor-Bandilla
- Citation
- G.R. No. 254546
- Court
- Supreme Court
- Decided
- August 9, 2023
Whether the marriage should be declared void due to psychological incapacity of the wife under Article 36 of the Family Code
Summary
The Supreme Court denied petitioner Ruel Anthony M. Bandilla's petition to declare his marriage to Mary Jane A. Obor-Bandilla void based on psychological incapacity under Article 36 of the Family Code. Despite being separated for over 13 years and evidence of troubled marriage including threats, financial irresponsibility, and extreme jealousy, the Court applied the Tan-Andal doctrine requiring clear and convincing evidence of psychological incapacity. The Court found that petitioner's testimony and a psychological report based on limited, one-sided information were insufficient to meet this evidentiary standard. While the Court acknowledged the petitioner's difficult situation and that personal examination of the allegedly incapacitated spouse is no longer required, it emphasized that evidence must come from multiple sources beyond just the petitioning spouse. The decision affirmed the Court of Appeals' reversal of the trial court's original grant of nullity, upholding the indissolubility of marriage absent sufficient proof of psychological incapacity.