G.R. No. 161793 - Ngo Te vs. Yu-Te

Edward Kenneth Ngo Te (25) and Rowena Ong Gutierrez Yu-Te (20) met in January 1996 at a Filipino-Chinese college gathering, grew close and, at Rowena’s insistence, eloped to Cebu in March 1996.
Lacking funds and employment, they returned to Manila in April 1996; Rowena’s threats of suicide and familial pressure compelled Edward to live at her uncle’s house.

On April 23, 1996, Rowena’s uncle brought them before a judge in Valenzuela City to solemnize their marriage without a license.
Edward was thereafter confined by Rowena’s family, intimidated with threats and firearms, until he escaped a month later and returned to his parents.
By June 1996, after unsuccessful efforts at reconciliation, Rowena agreed to live separate lives.

Edward filed a petition for annulment on January 18, 2000, alleging Rowena’s psychological incapacity under Article 36, Family Code (Civil Case No. Q-00-39720, RTC Quezon City, Br. 106).
The RTC ordered the City Prosecutor to probe collusion, OSG entered as counsel for the State, and investigators recommended trial on the merits.
A clinical psychologist evaluated both parties via tests (Revised Beta, Bender-Gestalt, Draw-A-Person, Rorschach, MMPI, etc.), concluding Edward suffered dependent personality disorder and Rowena narcissistic and antisocial personality disorder.
On July 30, 2001, the RTC declared the marriage null and void for mutual psychological incapacity.
The OSG appealed; the CA, in its August 5, 2003 decision, reversed the RTC, finding petitioner failed to prove Rowena’s incapacity (no personal examination, lack of gravity, juridical antecedence, incurability, and absence of OSG certification). The CA denied reconsideration on January 19, 2004.
The Supreme Court granted review on certiorari under Rule 45 on June 15, 2005.

Whether the marriage is void ab initio under Article 36 of the Family Code due to one or both parties’ psychological incapacity to assume essential marital obligations.

Whether the CA correctly applied the standards for proving psychological incapacity (personal examination, gravity, antecedence, incurability, OSG certification).