G.R. No. 203992 - Antonio S. Quiogue, Jr. vs. Maria Bel B. Quiogue and the Republic

Antonio S. Quiogue, Jr. (petitioner) and Maria Bel B. Quiogue (respondent) married on October 16, 1980.
They have four children: Marie Antonette, Jose Antonio, Anabel, and Maritoni.
The spouses have been separated since 1998 when Maribel drove Antonio out of the conjugal home.
Antonio temporarily stayed in his office at Nacional Memorial Homes and later moved to a condominium in Quezon City.

Antonio filed a Petition for Declaration of Nullity of Marriage, alleging psychological incapacity of both parties to comply with essential marital obligations including mutual love, respect, and moral support.
He claimed attempts at reconciliation failed.

Maribel denied driving Antonio out, stating he left voluntarily due to womanizing and nocturnal gambling.
She alleged Antonio’s behavior included coming home drunk, violent threats, verbal abuse, and humiliating her before children and neighbors.

Public prosecutor reported no collusion between parties.
Pre-trial efforts at reconciliation were unsuccessful; cooling-off period was given.
Antonio testified to Maribel’s ill-tempered and confrontational nature, and her demeaning behavior towards him, including exposing his affairs through pictures and obscene messages.
Antonio admitted to infidelity but viewed his wife's reaction as aggravating.
Witness Gemarie Martin confirmed Maribel's suspicious calls to Antonio's office and sending vulgar faxes.
Psychiatrist Dr. Valentina Del Fonso Garcia conducted mental status assessment and psychiatric interviews with Antonio, Maribel, and their children, recommending nullification due to psychological incapacity.

Maribel claimed her interview with Dr. Garcia was only in context of their daughter Anabel’s depression, not their marriage.
She denied being suspicious and stated that Antonio’s multiple affairs were uncovered through anonymous tips.
Alleged Antonio’s cohabitation with one Ynes Gamila, introduced as his cousin but effectively a paramour.

Eldest daughter Marie Antonette corroborated knowledge of Antonio’s girlfriends and the pain caused to Maribel.
She observed Ynes’ frequent presence in their home and family events.

On May 8, 2008, RTC declared the marriage null and void on grounds of psychological incapacity of both spouses.
Dr. Garcia’s evaluation found Antonio suffered from narcissistic and histrionic personality disorder with chronic infidelity, and Maribel had extreme emotional reactions including public humiliation of her husband.
Both were found incapacitated to comply with essential marital obligations of love, respect, fidelity, and mutual support.

The Court of Appeals reversed the RTC ruling, holding that Antonio’s infidelity and irreconcilable differences did not suffice to prove psychological incapacity under Article 36 of the Family Code.
It found Dr. Garcia’s report inconclusive as proof.
The petition was dismissed, and subsequent motion for reconsideration was denied.

Antonio sought reversal of the CA decision.
Solicitor General opposed, asserting failure to establish gravity, antecedence, and incurability of psychological incapacity.
Argued that infidelity alone does not constitute psychological incapacity, and Maribel’s ill-tempered behavior was a reaction to Antonio’s wrongdoings.
Raised methodological flaws in Dr. Garcia’s psychiatric evaluation.

Whether or not petitioner Antonio’s chronic infidelity and the circumstances of the marriage amount to psychological incapacity under Article 36 of the Family Code.
Whether Maribel’s ill-tempered and confrontational behavior constitutes psychological incapacity.
Whether Dr. Garcia’s psychiatric evaluation is a sufficient and reliable basis to establish psychological incapacity.
Whether the CA erred in dismissing the petition for declaration of nullity of marriage.