G.R. No. 47722 - People vs. Oanis

Maria Vicia Carullo-Padua (Maria) and Joselito Padua (Joselito) were married in a civil ceremony on February 5, 1982, followed by a church wedding on December 18, 1982.
The marriage produced one son born on March 23, 1986.

On July 17, 1997, Maria filed a petition for declaration of absolute nullity of marriage against Joselito before the Regional Trial Court (RTC) of Las Piñas City, relying on Article 36 of the Family Code.
Maria alleged psychological incapacity on Joselito’s part to comply with essential marital obligations, citing:

Joselito’s excessive sexual desire, compelling her to perform oral and anal sex;
His attempts to sexually molest her sister, nieces, and household help;
Misrepresentation of his religion as Roman Catholic while being a Born-again Christian, leading to religious insults when Maria refused to convert;
An incident where Joselito threatened her life with a letter opener during a quarrel;
Failure to provide financial support and dependency on Maria’s parents;
Neglect in finding or maintaining employment and absence of emotional support to their son;
Abandonment by working abroad without prior consultation and cessation of financial support;
Joselito’s 1992 letter admitting to shortcomings and severing ties with Maria and their child;
Joselito seeking custody of the child upon his return in 1997.

Joselito did not file an answer; the court ordered the public prosecutor to investigate possible collusion.
Trial proceeded in Joselito’s absence after the public prosecutor found no collusion.
In opposition, the Office of the Solicitor General filed a comment against the petition.
Maria and psychiatrist Dr. Cecilia Villegas testified. Dr. Villegas based her diagnosis of Joselito as having a sexual deviant personality disorder on Maria’s narrations, citing his perversion rooted in a troubled childhood with emotional confusion from parental dynamics. The disorder was deemed grave, serious, and incurable, rendering Joselito psychologically incapacitated.

On September 2, 1999, the RTC denied the petition, holding that the evidence failed to overcome the presumption of validity of marriage.
The court regarded the evidence as proving infidelity and sexual perversion but not grave psychological incapacity existing at the time of marriage.
The expert’s diagnosis was based solely on petitioner’s narratives, thus questionable in veracity.

Maria appealed; the Court of Appeals (CA) affirmed the RTC’s ruling, holding the grounds relied upon—sexual perversion, abandonment, attempt on life, infidelity—do not constitute psychological incapacity under Article 36 but grounds for legal separation under Article 55.
A motion for reconsideration was denied by the CA on November 14, 2011.

Failure to consider undisputed evidence; reliance on mere presumptions;
Sadism as a sexual anomaly that constitutes psychological incapacity;
Clear and convincing proof of psychological incapacity, personality disorder, deviance, and incurability;
Joselito’s incapacity to perform essential marital obligations due to sexual deviance and perversion.

Whether the totality of evidence presented by Maria is sufficient to prove Joselito’s psychological incapacity to perform his essential marital obligations, justifying the declaration of nullity of their marriage under Article 36 of the Family Code.