Facts:

The case involves Ma. Virginia D.R. Halog as the petitioner and Wilbur Francis G. Halog, along with the Republic of the Philippines, as respondents. The events leading to this case began with the marriage of Ma. Virginia and Wilbur on June 12, 1993. Their relationship, which started positively, deteriorated over time due to frequent misunderstandings and Wilbur's temperamental behavior. Ma. Virginia discovered Wilbur's infidelity before their wedding but chose to proceed with the marriage to avoid family shame. The couple faced numerous conflicts, with Wilbur expressing regret over the marriage and engaging in extramarital affairs, which he continued even after they had children.

In 2005, Wilbur went to Qatar for work, initially improving their communication, but this soon deteriorated as he became verbally abusive, particularly when Ma. Virginia made mistakes in managing his business. Wilbur's lack of concern for their children, especially when their daughter ...

Facts:

Background of the Case

Ma. Virginia D.R. Halog filed a petition for the declaration of nullity of her marriage with Wilbur Francis G. Halog on the ground of psychological incapacity under Article 36 of the Family Code. Wilbur failed to file an answer to the petition. The trial court granted the petition, but the Court of Appeals reversed the decision.

Relationship and Marriage

Ma. Virginia and Wilbur met through a mutual friend and eventually became sweethearts. Despite discovering Wilbur’s infidelity before their wedding, Ma. Virginia proceeded with the marriage in 1993 to avoid family shame. The marriage was marred by frequent arguments, Wilbur’s temper, and infidelity. Wilbur admitted regretting the marriage and being unprepared for marital responsibilities.

Marital Issues

Wilbur neglected his family, engaged in repeated extramarital affairs, and became physically abusive. He even pointed a gun at Ma. Virginia during a heated argument. When Wilbur went to Qatar for work, their relationship briefly improved, but he eventually abandoned the family and married another woman in 2006.

Psychological Evaluations

Dr. Melchor C. Gomintong conducted a psychiatric evaluation of Ma. Virginia and diagnosed Wilbur with Antisocial Personality Disorder based on collateral interviews. Ma. Virginia was diagnosed with Avoidant Personality Disorder. Wilbur did not submit to evaluation.

Issue:

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Ruling:

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Ratio:

1. Psychological Incapacity as a Legal Concept
   Psychological incapacity, as clarified in Tan-Andal v. Andal, is a legal concept, not a medical condition. It refers to a spouse’s inability to fulfill essential marital obligations due to a durable aspect of their personality structure. Expert testimony is not mandatory, and ordinary witnesses can testify to the spouse’s behavior.

2. Manifestations of Wilbur’s Incapacity
   Wilbur’s abusive behavior, repeated infidelity, neglect of family responsibilities, and abandonment clearly manifested his psychological incapacity. These acts were consistent and demonstrated his inability to comply with marital obligations.

3. Juridical Antecedence, Gravity, and Incurability

   • Juridical Antecedence: Wilbur’s behavior, including his infidelity and abusive tendencies, existed before the marriage.
   • Gravity: His actions were not mild but grave, including physical abuse and abandonment.
   • Incurability: Wilbur’s behavior was persistent and enduring, leading to the inevitable breakdown of the marriage.

4. Role of Expert Testimony
   Dr. Gomintong’s evaluation, though based on collateral interviews, was credible as it followed sound methodologies. However, even without expert testimony, the testimonies of Ma. Virginia and her witnesses were sufficient to establish Wilbur’s psychological incapacity.

5. Essential Marital Obligations
   Wilbur failed to fulfill his obligations under Articles 68 to 71, 220, 221, and 225 of the Family Code, including mutual love, respect, fidelity, and support for his family.

6. Protection of Individual Dignity
   The Court emphasized that Article 36 protects an individual’s right to liberty and dignity. Ma. Virginia should not be compelled to remain in a dysfunctional and abusive marriage.