G.R. No. 7987 - Behn Meyer and Co., Ltd. vs. Collector of Customs

Petitioner Abigael An Espina-Dan, a Philippine national, and respondent Marco Dan, an Italian national, first met online in May 2005 through a chatroom.
The parties developed a relationship characterized by regular online communication and exchange of letters, which deepened their emotional connection despite being in different countries.
In November 2005, respondent proposed marriage, and the following year he traveled from Italy to the Philippines to get married.
The wedding took place on January 23, 2006, after which respondent immediately returned to Italy while petitioner later joined him on February 23, 2006.
The couple lived together in Italy where, according to petitioner’s account, various issues began to surface in respondent’s behavior.

Petitioner alleged that after a period of harmonious relations, respondent increasingly exhibited traits that she argued were indicative of psychological incapacity.

These traits included irresponsibility, immaturity, excessive dependence on his mother, neglect of household duties, and poor personal hygiene.
Specific behavioral issues noted were his refusal to be circumcised (a cultural issue in Europe), excessive video game playing, and alleged drug (marijuana) use.

Petitioner further contended that these behaviors, which emerged after the marriage, were reflective of a grave, permanent, and incurable psychological disorder that had existed from the onset of their marital union.

Petitioner filed a Petition for Declaration of Nullity of Marriage on September 14, 2007, in the RTC of Las PiAs City (Civil Case No. LP-07-0155).
The evidence was primarily in the form of:

Petitioner’s own judicial affidavit detailing her experience and observations during court proceedings.
The testimony of her mother, Violeta G. Espina, which reiterated the behavioral issues and lack of marital support.
The clinical evaluation and testimony of psychologist Nedy Tayag, who, based on interviews of petitioner and her mother (without directly examining respondent), diagnosed respondent with Dependent Personality Disorder with Underlying Anti-Social Traits.

Despite these allegations, petitioner also admitted that before the problems surfaced, respondent had been romantic, responsible, and provided financial support.

The RTC rendered a decision on January 4, 2010, dismissing the petition for nullity on the ground that petitioner’s evidence failed to prove respondent’s alleged psychological incapacity.
Petitioner sought reconsideration in April 2010, which was denied by the RTC.
The petition was subsequently appealed to the Court of Appeals (CA), which, in the December 14, 2012 Decision, upheld the RTC ruling, finding insufficient evidence for annulment on psychological incapacity grounds.
A further resolution on August 29, 2013, by the CA reiterated its stance, leading to the petition for review before the Supreme Court, which ultimately denied the petition.

The evidence presented by petitioner was largely one-sided and primarily based on her personal testimony and that of her immediate family, without independent or direct psychological examination of respondent.
Cultural differences, such as views on circumcision and personal hygiene prevalent in Italy versus the Philippines, were noted and considered by the courts.
The overall factual record indicated that, despite the later issues, there was a period of harmonious marital relations that conflicted with the claim of an inherent, pre-existing psychological incapacity.

Whether petitioner’s evidence was sufficient to establish that respondent had a psychological incapacity that was grave, pre-existing (juridically antecedent to the marriage), and incurable, in accordance with Article 36 of the Family Code and the guidelines laid down in Santos v. Court of Appeals.
Whether the alleged behavioral traits (irresponsibility, addiction to video games and drugs, dependence on his mother, and poor personal hygiene) constitute the level of psychological incapacity required to nullify the marriage.

Whether a psychological diagnosis based solely on third-party accounts (from the petitioner and her mother), without direct examination of respondent, meets the rigorous standards required by precedent.
Whether the absence of direct, comprehensive psychological testing on respondent affected the credibility and sufficiency of the expert’s diagnosis.

Interpretation of Marital Obligations and the Ground of Psychological Incapacity

Whether incompatibility or failure to consistently perform marital obligations—stemming from personal or cultural differences—can be legally equated with a psychological incapacity that renders a marriage void from the outset.