G.R. No. 176464 - Lim vs. Sta. Cruz-Lim

Petitioner Edward N. Lim and respondent Maria Cheryl Sta. Cruz-Lim’s relationship began in 1978 in Cebu during the petitioner’s semestral break from college.
The parties met under ordinary circumstances, with the petitioner working in the family business and the respondent studying secretarial courses.
After less than a year of long-distance courtship carried out primarily through phone calls, the couple formalized their relationship.
Their marriage was solemnized on December 8, 1979, at Don Bosco Church in Makati City with a subsequent reception held at Midtown Ramada Hotel.
In keeping with their Chinese cultural practices, the couple resided with the petitioner’s grandparents and parents in Forbes Park, Makati City.

The couple had three children: Lester Edward, Candice Grace, and Mariano III.
All household, living, and medical expenses were provided by petitioner’s grandparents, while petitioner’s salary was consistently turned over to the respondent.
Despite the comfortable amenities, respondent expressed discontent with the living arrangement and persistently insisted on independent living away from petitioner’s family.
Tensions escalated when, on October 14, 1990, respondent registered a police complaint after allegedly witnessing petitioner in a compromising situation with a household caregiver, an incident that was widely publicized in the media.
On the same day, respondent left petitioner, taking their three children and seizing important personal and official documents, including petitioner’s passport, jewelry, and a land title.

In the wake of the separation, respondent initiated criminal and civil actions against the petitioner.

A criminal complaint for concubinage and physical injuries was filed but later dismissed for lack of merit.
A separate support action was instituted against petitioner and his parents, resulting in a court order directing monthly support payments for the children and respondent.

On October 29, 1999, petitioner filed a petition for the nullity of marriage based on respondent’s psychological incapacity under Article 36 of the Family Code.
In July 2002, petitioner amended his petition to include allegations of his own psychological incapacity, asserting that both parties suffered from personality disorders.

The petitioner presented evidence in support of his claim through the testimony of Dr. Cecilia C. Villegas, a psychiatrist, and an additional co-worker witness, Maxima Adato.
Dr. Villegas produced a Psychiatric Report which diagnosed petitioner with Dependent Personality Disorder and respondent with Histrionic Personality Disorder associated with immaturity.
The report elaborated on the “psychodynamics of the case,” citing:

For petitioner: A background marked by overindulgence and overprotection by surrogate parents, resulting in dependency, lack of self-confidence, passivity, and depression.
For respondent: An upbringing with fractured family relationships where a stepfather figure entered a context of insufficient parental attention, leading to attention-seeking behavior.

The clinical evidence underlined that both personality disorders were permanent, severe, and established prior to the marriage, though manifesting more clearly under the pressures of marital life.
During trial, Dr. Villegas testified based on three focused sessions with petitioner and an interview of a long-time employee, while the respondent’s perspective was gathered second-hand through the petitioner.
Notably, limitations in the psychiatric evaluation surfaced during cross-examination, including the absence of comprehensive psychological tests and reliance predominantly on interviews and information supplied by petitioner.

The Regional Trial Court (RTC) declared the marriage null and void ab initio on the ground of psychological incapacity of both parties, ordering collateral measures such as the cancellation of the marriage entry in civil registries and the liquidation of the conjugal partnership.
The Office of the Solicitor General (OSG) vigorously opposed the RTC’s finding, leading the Court of Appeals (CA) to reverse the RTC decision, affirming that the marriage was subsisting and valid.
The CA’s reversal was based on insufficiency in the evidence connecting the alleged personality disorders to an incapacity to perform the essential marital obligations.

Whether the marriage between petitioner and respondent can be declared null and void on the ground of psychological incapacity under Article 36 of the Family Code.

Whether the psychiatric evidence, particularly the conclusions of Dr. Villegas, sufficiently established that both parties suffered from grave, pre-existing, and incurable personality disorders.
Whether the trial court erred in linking the manifested personality disorders to an inability to comply with the essential marital obligations.
Whether the evidentiary limitations in the psychiatric evaluation (such as lack of comprehensive testing and reliance on interviews) undermined the proper adjudication of psychological incapacity.