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

Petitioner Antonio S. Quiogue, Jr. filed a Petition for Declaration of Nullity of Marriage against his wife, respondent Maria Bel B. Quiogue, alleging that both parties were psychologically incapacitated to meet the essential marital obligations.

The marriage was solemnized on October 16, 1980, and the couple had four children. The relationship deteriorated over time, leading to an actual separation in fact since 1998.

Antonio claimed that both he and Maribel suffered from psychological incapacity, which he argued rendered them unable to live together in accordance with the marital duties of love, respect, fidelity, and mutual support.

He contended that Maribel’s behavior—her ill temperament, public demeaning of him, and intrusive conduct (such as calling his office to inquire about his whereabouts)—undermined the marriage.

Antonio admitted to engaging in extramarital affairs; however, he argued that these were not mere indiscretions but manifestations of a deep-seated personality disorder that was present even before their marriage.

Maribel denied driving Antonio out of the conjugal home, asserting that it was his own choice to leave due to his womanizing, nocturnal gambling, and erratic behavior.

She further argued that his repeated acts of infidelity, rather than her retaliatory actions (such as sending vulgar fax messages and letters), were the primary source of marital discord.

Maribel maintained that her emotional reactions were those of a wronged spouse and did not amount to psychological incapacity.

A key piece of evidence was the Psychiatric Evaluation conducted by Dr. Valentina Del Fonso Garcia, which involved clinical interviews with both Antonio and members of the family, including their eldest daughter.

In her evaluation, Dr. Garcia found that Antonio suffered from a narcissistic and histrionic personality disorder, significantly affecting his behavior and his ability to fulfil his marital obligations.

The evaluation highlighted Antonio’s chronic infidelity as deeply rooted in his dysfunctional personality, which had antecedents dating back to his childhood and adolescence, including exposure to his own father’s infidelities.

At the trial level, the Regional Trial Court (RTC) ruled in Antonio’s favor by declaring the marriage null and void on the ground of psychological incapacity under Article 36 of the Family Code.

The Court of Appeals (CA) later reversed the RTC’s ruling, holding that Antonio’s infidelity did not amount to psychological incapacity as defined by the legal requirements, and that the evidence from the psychiatric evaluation only confirmed existing marital problems.

After the CA denied Antonio’s motion for reconsideration, he elevated the case to the Supreme Court for review under Rule 45 of the Rules of Court.

Whether the acts constituting chronic infidelity and the accompanying dysfunctional behavior of Antonio amount to psychological incapacity under Article 36 of the Family Code.
Whether psychological incapacity, as a ground for nullity, can be established through the totality of evidence including testimonial and psychiatric evaluation evidence, without necessarily relying on a contemporary clinical examination of both spouses.
Whether the allegations and evidence concerning Maribel’s retaliatory actions and emotional outbursts suffice to surmount the threshold of psychological incapacity or are merely consequences of the petitioner’s own conduct.
Whether the requisites of gravity (seriousness of the incapacity), antecedence (existence at the time of the marriage), and legal incurability (persistence of incapacity) are adequately demonstrated in this case.