Facts:

The case involves Edward N. Lim as the petitioner and Ma. Cheryl Sta. Cruz-Lim as the respondent. The events leading to the case began in 1978 when Edward, a 26-year-old college student from Makati City, met Cheryl, a secretarial student from Gingoog City, Cagayan de Oro, while spending a semestral break in Cebu. After a year of long-distance courtship, they married on December 8, 1979, at Don Bosco Church in Makati City. They lived with Edward's grandparents in Forbes Park, Makati City, and had three children: Lester Edward, Candice Grace, and Mariano III. Despite the financial support from Edward's family, Cheryl expressed dissatisfaction with their living arrangements and insisted on living independently.

The marriage faced turmoil on October 14, 1990, when Cheryl reported Edward to the police for an alleged compromising situation with a caregiver, which was subsequently published in a tabloid, causing public embarrassment. That same day, Cheryl left Edward, taki...

Facts:

Background of the Parties

• Petitioner Edward N. Lim and respondent Maria Cheryl Sta. Cruz-Lim met in 1978 in Cebu. Edward was a 26-year-old college student working in the family business, while Cheryl was a secretarial student.
• They began a long-distance courtship and married on December 8, 1979, at Don Bosco Church in Makati City. They lived with Edward's grandparents and parents in Forbes Park, Makati, and had three children.

Marital Issues

• Cheryl was dissatisfied with living with Edward's family and insisted on living independently. Despite financial support from Edward's family, conflicts arose.
• On October 14, 1990, Cheryl reported an incident to the police where she caught Edward in a compromising situation with their caregiver. This incident was published in a tabloid, causing embarrassment to Edward and his family.
• Cheryl left Edward, taking their three children and some of Edward's personal belongings, including his passport and land title. She also filed criminal charges against Edward, which were later dismissed.

Legal Proceedings

• Cheryl filed a case for support against Edward and his parents. The court ordered Edward to provide monthly support, with his parents as secondary obligors.
• On October 29, 1999, Edward filed a petition for the nullity of their marriage under Article 36 of the Family Code, citing psychological incapacity. He later amended the petition to include his own psychological incapacity, as both he and Cheryl were diagnosed with personality disorders (dependent personality disorder and histrionic personality disorder, respectively).

Expert Testimony

• Edward presented Dr. Cecilia C. Villegas, a psychiatrist, who testified that both parties suffered from personality disorders that rendered them psychologically incapacitated to fulfill marital obligations. Cheryl waived her right to present evidence.

RTC Decision

• The RTC declared the marriage null and void based on the psychiatric report, ruling that both parties were psychologically incapacitated. The court also addressed custody and property division.

CA Decision

• The Court of Appeals reversed the RTC decision, finding that the evidence did not sufficiently prove psychological incapacity under Article 36 of the Family Code. The CA declared the marriage valid and subsisting.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Requirements for Psychological Incapacity:

   • The Supreme Court reiterated the three criteria for psychological incapacity established in Santos v. Court of Appeals: (1) gravity, (2) juridical antecedence, and (3) incurability.
   • The incapacity must be grave, rooted in the party's history before the marriage, and incurable or beyond the party's means to cure.

2. Insufficiency of Evidence:

   • The psychiatric report and testimony of Dr. Villegas were deemed insufficient to prove psychological incapacity. The report lacked a clear link between the parties' alleged personality disorders and their inability to fulfill marital obligations.
   • Dr. Villegas' conclusions were based primarily on interviews with Edward and his employee, without corroboration from Cheryl or her relatives. The absence of psychological tests further weakened the findings.

3. Expert Testimony:

   • The Court emphasized that expert testimony must be supported by factual evidence and proper psychological testing. Dr. Villegas' testimony, based on limited interviews and without collaboration with psychologists, did not meet this standard.
   • The Court also noted that the trial court should not rely solely on expert opinions but must independently assess the evidence.

4. Legal and Jurisprudential Standards:

   • The Court highlighted that psychological incapacity must be proven by clear and convincing evidence. The burden of proof lies with the party alleging incapacity, and the evidence must meet the stringent requirements set by jurisprudence.

5. Conclusion:

   • The Supreme Court found that Edward failed to prove that he and Cheryl were psychologically incapacitated to fulfill their marital obligations. The marriage was declared valid, and the petition was denied.