Title
Supreme Court
Laroco vs. Laroco
Case
G.R. No. 253342
Decision Date
Jun 22, 2022
Petitioner sought nullity of marriage based on psychological incapacity; SC redefined psychological incapacity, found mutual antagonism, and declared marriage void.

Case Digest (G.R. No. 253342)
Expanded Legal Reasoning Model

Facts:

  • Background and Marriage
    • Petitioner Dionisio C. Laroco met respondent Aurora B. Laroco in 1970 as students. They courted and became a couple, but petitioner broke up after learning respondent entertained other suitors.
    • Petitioner's parents disapproved of respondent due to her reputation.
    • Petitioner went to Manila to support respondent's mother undergoing cobalt therapy.
    • Respondent became pregnant and insisted on marriage; her parents forced petitioner to marry her in Mankayan, Benguet, on September 6, 1971.
    • They had three children born in 1972, 1973, and 1977.
  • Marital Life and Conflicts
    • Petitioner’s mother died in 1973; respondent moved to Baguio but stayed separately due to dislike from petitioner’s father.
    • Respondent managed a canteen and continued to date other men, deceived petitioner, and incurred debts.
    • Petitioner confronted respondent but was met with denial and lack of accountability.
    • Respondent got arrested for estafa related to unpaid jewelry purchases; petitioner raised bail but respondent did not return home afterward.
    • Respondent lived with her paramour; children later lived with petitioner due to maltreatment by paramour.
  • Psychological Evaluation
    • Petitioner consulted psychiatrist Dr. Clarette Rosario Dy who diagnosed petitioner with obsessive-compulsive personality disorder and respondent with histrionic personality disorder.
    • Diagnoses highlighted traits such as perfectionism and rigidity for petitioner, and need for attention and superficial emotions for respondent.
    • Dr. Dy concluded both spouses were psychologically incapacitated at the time of marriage with permanent and grave personality disorders, making them unfit for marital obligations.
  • Trial and Appeal
    • Petitioner filed a petition for nullity of marriage due to psychological incapacity under Article 36 of the Family Code.
    • Respondent failed to file an answer.
    • RTC denied the petition on grounds that evidence was insufficient to prove grave, incurable psychological incapacity.
    • Court of Appeals affirmed the RTC decision, citing lack of sufficient proof and credibility issues in psychiatric report.
  • Present Petition
    • Petitioner sought review, arguing sufficient evidence proved grave and incurable psychological incapacity of both spouses pre-existing marriage.

Issues:

  • Whether the marriage should be declared null and void on the ground of psychological incapacity under Article 36 of the Family Code.
  • Whether the totality of evidence presented by petitioner proves grave, incurable psychological incapacity that existed at the time of marriage.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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