Dytianquin vs. Dytianquin

Facts:

The dispute arises from a petition for declaration of absolute nullity of marriage filed in the Regional Trial Court (RTC), Branch 136, Makati City. In February 2013, Eduardo Dytianquin instituted Civil Case No. 13-178 under Article 36 of the Family Code, alleging that both he and his wife, Maria Elena Bustamante Dytianquin, were psychologically incapacitated to assume the essential obligations of marriage. He attached a psychological assessment by clinical psychologist Dr. Nedy L. Tayag diagnosing him with Passive-Aggressive Personality Disorder and his wife with Narcissistic Personality Disorder, and averred that these disorders were grave, antecedent to the marriage, and incurable.

The RTC, in a Decision dated September 15, 2014, dismissed Eduardo’s petition, finding that the parties’ conduct showed refusal or unwillingness to perform marital obligations rather than a debilitating psychological condition rendering them incapable of fulfilling such obligations. The RTC denied Eduardo’s motion for reconsideration in an Order dated July 13, 2015. Eduardo appealed to the Court of Appeals (CA), which in a Decision dated March 15, 2017 (CA‑G.R. CV No. 105382), granted the appeal and declared the marriage void on the ground that both parties were psychologically incapacitated, giving weight to Dr. Tayag’s diagnoses and finding the disorders sufficiently linked to the parties’ inability to perform essential marital duties. The CA denied Elena’s motion for reconsideration in a Resolution dated September 4, 2017.

Elena, through a petition for review on certiora...(Pro-only)

Issues:

• Did the plaintiff (Eduardo) carry the burden of proof to establish psychological incapacity under Article 36 of the Family Code?
• Did the Court of Appeals correctly declare the marriage void on the ground that both spouses were psychologically incapacitated to fulfill essential...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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