G.R. No. 240802 - Montealto-Laylo vs. Ymbang

Rena Montealto-Laylo, the petitioner, filed a petition for declaration of nullity of her marriage with Thomas Johnson S. Ymbang on the ground of psychological incapacity under Article 36 of the Family Code.
The marriage was solemnized on December 23, 2010 in Dubai, United Arab Emirates, following Thomas’ divorce from his previous wife.
Soon after the marriage, Rena remained in Dubai while Thomas returned to the Philippines due to health issues and visa complications.

Rena supported her petition by submitting a Psychiatric Report dated March 1, 2016, prepared by Dr. Romeo Z. Roque.

Dr. Roque conducted interviews and examinations involving Rena, her brother Gilbert Laylo, and a common friend of the spouses.
In his report, Dr. Roque diagnosed Rena with Borderline Personality Disorder, noting manifestations such as extreme jealousy, suicidal threats, emotional instability, refusal to communicate with Thomas, self-harm, and an alleged involvement with another man.

Rena and other relatives (notably her sister-in-law, Racquel Laylo) submitted Judicial Affidavits to corroborate the manifestations of her disorder.
Dr. Roque also identified that Thomas exhibited traits indicative of Dependent Personality Disorder, which manifested through indecisiveness and an excessive reliance on family opinions, although this was less severe in context.

The Regional Trial Court (RTC) of Lemery, Batangas, rendered a decision on August 4, 2016 declaring the marriage null and void due to the psychological incapacities of both spouses.

The RTC found that Thomas’ previous marital failure and Rena’s extreme manifestations of Borderline Personality Disorder evidenced their incapacity to perform marital obligations.
The decision ordered the expunging of the marriage record by the Department of Foreign Affairs and the Philippine Statistics Authority.

The Office of the Solicitor General (OSG) filed a motion for reconsideration with the RTC, which was denied by an Order dated December 22, 2016.
The Court of Appeals (CA) reversed the RTC’s decision on April 13, 2018, dismissing the complaint for nullity on the ground that the evidence did not prove grave psychological incapacity by clear and convincing evidence.

The CA ruled that Rena’s personal issues, such as spending time with peers and her emotional outbursts, were insufficient to establish an outright incapacity, viewing these behaviors as isolated instances of marital non-performance.
The CA noted that Thomas’ behavior did not rise to the level of incapacity.

Rena then filed the petition for review on certiorari with the Supreme Court challenging the CA’s ruling, arguing that the appellate court had disregarded expert findings and factual determinations made by the RTC.

Whether the Court of Appeals erred in reversing the RTC’s decision by dismissing the petition for nullity of marriage on the ground of psychological incapacity.

Whether the evidence, particularly the expert Psychiatric Report and Judicial Affidavits, sufficiently established that Rena (and to a lesser extent, Thomas) possessed a psychological incapacity grave enough to nullify the marriage.
Whether the CA correctly interpreted and applied the requirements under Article 36 of the Family Code, including the thresholds of clear and convincing evidence and the concept of incurability, as guided by the evolving jurisprudence (e.g., the Tan-Andal and Molina guidelines).