Facts:

The case of Rodolfo A. Aspillaga vs. Aurora A. Aspillaga arose following the couple's tumultuous marriage, which began when they were married in 1980 after meeting as students in the 1970s. Over the years, the relationship became strained due to Rodolfo's allegations of Aurora's domineering behavior and issues related to jealousy, spendthrift tendencies, and disagreements on familial decisions. Rodolfo left the conjugal home and filed for annulment on March 7, 1995, claiming psychological incapacity on Aurora's part. Aurora alleged that Rodolfo's infidelity with her cousin and subsequent abandonment in 1992 was the cause of their marriage’s disintegration. During the trial, both parties underwent psychiatric evaluations. The Regional Trial Court (RTC) initially ruled in favor of Rodolfo, citing both parties as psychologically incapacitated to fulfill marital obligations. However, this decision was appealed to the Court of Appeals, which reversed the RTC's

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Facts:

Background of the Relationship

• Rodolfo A. Aspillaga (petitioner) and Aurora A. Aspillaga (respondent, née Aurora Apon) met in 1977 while they were students at the Philippine Merchant Marine Academy and Lyceum of the Philippines, respectively.
• After a courtship lasting about five months, they became sweethearts.
• Aurora departed for Japan to study Japanese culture, literature, and language, yet the couple maintained communication during her absence.

The Marriage and Early Years

• Upon Aurora’s return from Japan in 1980, the couple got married.
• They had two children, and initial evidence showed a harmonious marital life characterized by mutual love and cooperation.
• Documents such as a letter dated April 1, 1990, indicate that the couple enjoyed a blissful union, fulfilling their marital obligations faithfully.

Marital Discord and Allegations

• Petitioner later portrayed the marriage as tumultuous, alleging that:
• Aurora was domineering, tactless, and overly controlling in family decisions.
• She was a spendthrift and at times humiliated him, including incidents occurring before friends.
• Aurora exhibited jealousy, suspicion, and was given to nagging.
• Aurora, in her version, asserted that in 1991:
• After a business trip to Japan—facilitated by a plane ticket allegedly given by Rodolfo—she discovered that Rodolfo had brought her cousin, Lecita Rose A. Besina, into their conjugal home as his concubine.
• This cohabitation led to the disintegration of their marriage, culminating in their separation and eventual abandonment of the conjugal home by Rodolfo in May 1992.

Petition for Annulment and Psychiatric Evaluations

• On March 7, 1995, Rodolfo filed a petition for annulment on the ground of psychological incapacity, asserting that Aurora failed to comply with essential marital obligations.
• During the trial, expert witness Dr. Eduardo Maaba provided a psychiatric evaluation of both parties:
• For Rodolfo, Dr. Maaba described him as an intelligent yet egoistic adult with deep-seated insecurities, projecting a dominant persona to cover his inadequacies.
• For Aurora, a history of traumatic childhood experiences, including parental separation, harsh treatment by a surrogate sister, and an unsettling discovery of her true family background, were cited. She was noted to have low self-esteem, a tendency for self-dramatization, and immature relational patterns.
• The report concluded that both parties exhibited psychological handicaps but emphasized that such conditions did not necessarily meet the stringent criteria for psychological incapacity as a ground for annulment.

Court Proceedings

• On May 31, 2000, the Regional Trial Court (RTC) found that both parties were psychologically incapacitated to enter into marriage, effectively annulling the union.
• On appeal, the Court of Appeals reversed the RTC decision in its September 9, 2005, ruling, declaring the marriage valid.
• Petitioner’s subsequent motion for reconsideration was denied in a Resolution dated December 20, 2005.

Additional Evidence and Context

• Evidence depicted a initially harmonious marriage, with both parties acting conscientiously regarding their familial and economic responsibilities.
• Petitioner’s claims regarding Aurora’s handling of finances, while noted, were found insufficient to substantiate a claim of psychological incapacity.
• The marital difficulties, particularly those arising from financial disagreements, were treated as normal occurrences rather than factors that could nullify the marital bond under the requirements of Article 36 of the Family Code.

Issue:

Whether the appellate court correctly applied the definition of “psychological incapacity” under Article 36 of the Family Code, particularly with regard to:

• Determining if the alleged psychological conditions of either or both parties were grave, with juridical antecedence (existing prior to the marriage), and incurable.
• Establishing whether these psychological conditions rendered the parties incapable of performing the essential marital obligations at the time of the marriage.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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