G.R. No. 234462 - Dytianquin vs. Dytianquin

Eduardo and Elena first met in 1969 while in high school, with Eduardo as the senior and Elena as a sophomore, and they fell in love at first sight.
Despite the opposition of Elena’s parents—who preferred that she finish her studies—the couple eloped and were married on October 18, 1970, in Makati City.

For the initial months after marriage, the couple maintained a harmonious relationship.
Within a year, frequent and violent fights began to emerge:

Eduardo would leave the house during conflicts, staying with family members, and avoid confronting issues.
Elena persistently confronted Eduardo with invectives and insults, notably demeaning his family.

Over time, Eduardo grew resentful of Elena’s nagging attitude and distanced himself by spending more time with friends and relatives.
Disintegration of communication began in 1972 when Eduardo left the home, and Elena eventually discovered his extramarital affair.
In 1976, the couple formally separated after prolonged acrimonious relations.

On February 25, 2013, Eduardo filed a petition before the Regional Trial Court (RTC), Branch 136 of Makati City, for the declaration of absolute nullity of marriage under Article 36 of the Family Code.
He claimed that both he and Elena were psychologically incapacitated and unfit to perform the essential duties of marriage due to personality aberrations.

In support of the petition, Eduardo submitted a psychological assessment report by clinical psychologist Dr. Nedy L. Tayag:

The Report detailed behaviors such as Eduardo’s negative attitude, reluctance to engage in constructive dialogue, and Elena’s impulsivity and domineering behavior.

The RTC dismissed Eduardo’s petition on September 15, 2014, finding no evidence of a disordered personality that rendered either party completely unable to discharge marital obligations.
Eduardo’s motion for reconsideration before the RTC was denied in July 2015.
Eduardo then appealed, and on March 15, 2017, the Court of Appeals (CA) granted his appeal, setting aside the RTC ruling and declaring the marriage void based on the alleged psychological incapacity of both parties.
Elena, represented by the Office of the Solicitor General, later filed a motion for reconsideration before the CA, which was denied on September 4, 2017.

The petition for review on certiorari was filed challenging the CA’s decision, calling on the Supreme Court to determine whether the appellate court erred in declaring the marriage void under the framework of psychological incapacity.
The case involved detailed medical-psychological evaluations and a review of the parties’ testimonies relating to their marital conduct.

Whether the evidence presented was sufficient to establish that both Eduardo and Elena possessed a grave, severe, and incurable psychological incapacity to perform the essential marital obligations as required under Article 36 of the Family Code.

Did the psychological assessment by Dr. Tayag, which diagnosed personality disorders in both parties, meet the burden of proof for the nullity petition?
Is mere evidence of interpersonal conflict, refusal, or neglect of marital duties equivalent to psychological incapacity as defined by jurisprudence?

Whether the Court of Appeals erred in reversing the RTC’s decision and declaring the marriage null and void on the basis of the alleged psychological incapacity.