G.R. No. 109287 - People vs. Cuizon y Ortega

Janice Maristela-Cuan (petitioner) filed a petition for the declaration of nullity of her marriage to Marcelino A. Cuan, Jr. (respondent) on the ground of psychological incapacity under Article 36 of the Family Code.
Marcelino did not file an answer or present evidence despite notice.

Janice and Marcelino met in 1997 while playing lawn tennis.
Marcelino courted Janice, and after two months of courtship, Janice accepted his proposal.
Marcelino was overprotective and highly jealous throughout their relationship.
To address Marcelino’s anxiety and jealousy, they secretly married on June 20, 1997, without informing their parents.
After the wedding, they did not live together; no honeymoon took place, and they only saw each other after work or during weekends.

Marcelino’s jealousy escalated; he barred Janice from talking to other men and frequently became violent, physically hurting her.
They went to motels about five times but never consummated the marriage; Marcelino would attempt sex but suddenly stop.
Their last communication was in 1999 after an argument; they have since lived apart without contact.

Janette Velasco, a close friend, corroborated Janice’s account about Marcelino’s jealousy and their failure to live together or have children.
Dr. Nedy L. Tayag, a clinical psychologist with 40 years of experience, conducted clinical interviews and administered psychological tests to Janice; Marcelino refused to be examined.
Dr. Tayag diagnosed Janice with Passive-Aggressive Personality Disorder, marked by emotional instability and need for control.
Based on psychodynamic analysis and third-party information, Dr. Tayag found Marcelino to suffer from Paranoid Personality Disorder with narcissistic and antisocial features, characterized by suspicion, selfishness, emotional instability, and irresponsibility.
The disorders rendered both parties psychologically incapacitated, unable to perform essential marital obligations.

The court granted the petition, declaring the marriage void due to psychological incapacity of both spouses.
The court ordered the dissolution of their absolute community property.

The Court of Appeals reversed the decision, ruling that there was insufficient evidence that either party was psychologically incapacitated under Article 36.
It characterized Marcelino’s behavior as immaturity, and Janice’s passiveness as non-indicative of psychological disorder.
The motion for reconsideration was denied.

Janice filed a petition for review on certiorari before the Supreme Court, contesting the appellate ruling.
The Office of the Solicitor General (OSG) opposed, arguing that the evidence showed mere immaturity and refusal to fulfill marital duties, not psychological incapacity.

Whether the evidence presented sufficiently proves that Marcelino A. Cuan, Jr. (and/or Janice Maristela-Cuan) was psychologically incapacitated at the time of their marriage under Article 36 of the Family Code, justifying the declaration of nullity of their marriage.