G.R. No. 158896 - Carating-Siayngco vs. Siayngco

This is a petition for review on certiorari of the Court of Appeals’ decision reversing the dismissal by the RTC, Branch 102, Quezon City, of a petition for the declaration of nullity of marriage.
The nullity petition was filed by respondent Manuel Siayngco against petitioner Juanita Carating-Siayngco.
The couple was legally married at civil rites on June 27, 1973, and in a Catholic Church on August 11, 1973.
In 1977, the couple adopted a baby boy named Jeremy.

On September 25, 1997, after 24 years of marriage, respondent Manuel filed a nullity action on the ground of psychological incapacity of his wife, Juanita.
He alleged that since the inception of their marriage:

Petitioner Juanita exhibited an over-domineering and selfish nature.
She displayed extreme volatility, routinely engaging in outbursts characterized by yelling, throwing objects, and excessive quarrels over trivial matters such as household arrangements and cleanliness.
She lacked respect for his professional reputation and his role as a judge, often demeaning his position.
She failed to provide moral support, particularly during critical phases of his career and personal endeavors.

Respondent attributed her alleged psychological incapacity to a long-standing emotional trauma rooted in her childhood experiences with her parents, which he claimed precipitated resentment and vindictive behavior.
The petitioner (Juanita) countered by insisting that:

They remained a cohesive family unit, still living together.
She is a loving wife and mother who had supported him even amidst his admitted extra-marital affairs.
The allegations were a fabrication by respondent Manuel, designed to facilitate his desire for separation and a new family life.

The early difficulties in the marriage, including lack of acceptance by his parents, which coincided with the onset of questionable behavior from his wife.
Numerous incidents demonstrating his wife’s alleged irritable and obsessive behavior (e.g., disputes over household items and interactions with neighbors and tenants).
Money matters and specific instances where she allegedly undermined his professional achievements.

A clerk of court testified regarding petitioner Juanita’s behavior in the workplace.
Other witnesses recounted episodes illustrating petty quarrels and her critical demeanor.

Dr. Valentina Garcia, who evaluated both parties and opined that the marital problems were rooted in a partner relational issue compounded by individual maladaptive personality traits. Her report emphasized that the defects shown by both spouses did not conclusively amount to a psychological incapacity, particularly in the case of petitioner Juanita.
Dr. Eduardo Maaba, whose evaluation of petitioner Juanita concluded that she possessed the psychological capacity to meet the essential marital obligations, describing her as mature, nurturing, and resilient under stress.

The RTC, on January 31, 2001, denied respondent Manuel’s petition on the ground that the alleged psychological incapacity of petitioner Juanita was not sufficiently supported by the evidence.
The RTC highlighted that a normal couple may have disagreements and that transient or isolated behaviors (even if offensive) do not constitute a ground for nullity.
A motion for reconsideration was filed and denied.
On July 1, 2003, the Court of Appeals reversed the RTC decision, largely relying on Dr. Garcia’s psychiatric evaluation, and concluded that both parties exhibited psychological incapacity, therefore permitting the nullity of their marriage.

The petition for review was elevated to the Supreme Court challenging the Court of Appeals’ findings, particularly on the issue of petitioner Juanita’s alleged psychological incapacity.
The Supreme Court scrutinized the evidentiary basis, expert testimonies, and the application of the doctrinal prerequisites for psychological incapacity as prescribed under Article 36 of the Family Code.

Whether the totality of the evidence adduced is sufficient to sustain a finding of psychological incapacity on the part of petitioner Juanita.
Whether or not the lower courts correctly identified the root cause and the nature of the alleged psychological incapacity, including:

The requirement that such incapacity be pre-existent or manifest at the time of the marriage.
The necessity for the incapacity to be grave, incurable, and directly linked to the failure to comply with essential marital obligations.

Whether respondent Manuel’s allegations, centered mainly on disagreements and behavioral incompatibility aggravated by extra-marital affairs, meet the threshold of psychological incapacity for purposes of declaring the marriage null and void.