Facts:

• Ma. Virginia D.R. Halog (petitioner) sought to have her marriage with Wilbur Francis G. Halog (respondent) declared void ab initio on the grounds of psychological incapacity.
• The couple married on June 12, 1993, but their relationship was troubled by Wilbur's infidelity, abuse, and neglect.
• Ma. Virginia testified that Wilbur was temperamental, abusive, and unfaithful, even having an affair while they were preparing for their wedding.
• Despite these issues, Ma. Virginia went through with the marriage to avoid family shame.
• Their marriage was marked by frequent arguments, Wilbur's infidelity, and his eventual abandonment of the family when he moved to Qatar in 2005.
• Wilbur's psychological incapacity was supported by a psychiatric evaluation from Dr. Melchor C. Gomintong, who diagnosed Wilbur with Antisocial Personality Disorder based on interviews with Ma. Virginia and other witnesses.
• The Regional Trial Court-Branch 261, Pasig City, initially granted the petition, declaring the marriage null and void.
• The Court of Appeals reversed this decision, leading Ma. Virginia to seek the Supreme Court's intervention.

Issue:

• (Unlock)

Ruling:

• The Supreme Court granted the petition, reversing the Court of Appeals' decision and reinstating the Regional Trial Court's ruling.
• The marriage between Ma. Virginia D.R. Halog and Wilbur Francis G. Halog was declared void ab initio on the ground of Wilbur...(Unlock)

Ratio:

• The Supreme Court's decision was based on the legal concept of psychological incapacity as outlined in Article 36 of the Family Code, further clarified in the landmark case of Tan-Andal v. Andal.
• The Court emphasized that psychological incapacity should be understood as a legal concept rather than a medical one, and it does not require clinical diagnosis to be established.
• The testimonies of Ma. Virginia and her witnesses were sufficient to prove Wilbur's ps...continue reading