Case Digest (G.R. No. 167391)
Facts:
John Arnel H. Amata (respondent) and Haydee N. Amata (Haydee) started their relationship while studying at the Pamantasan ng Lungsod ng Maynila, eventually marrying and having three children. Initially, their marriage was harmonious, but it soon soured as respondent felt that Haydee became too dominant, outspoken, and lacked emotional intimacy in their sexual relationship. Despite talking about these issues, Haydee's detrimental behavior continued. In 2003, while attending a workshop in Iloilo City, respondent formed a friendship with another woman, which Haydee discovered, leading to distrust and confrontation. Following this, respondent left their home to avoid conflict, leading Haydee to accuse him of infidelity. Their relationship deteriorated, prompting respondent to consult clinical psychologist Dr. Elena A. Del Rosario.
On October 13, 2008, respondent filed a petition for declaration of nullity of marriage, invoking psychological incapacity under Article 36 of the Fa
...Case Digest (G.R. No. 167391)
Facts:
John Arnel H. Amata and Haydee N. Amata, former sweethearts from their Pamantasan days, eventually married and had three children. In the early years the marriage was harmonious, but as time elapsed, conflicts emerged over personality clashes and perceived deficiencies in marital relations. Respondent Amata complained about his wife’s domineering and unsympathetic behavior and alleged that their sexual intimacy had become unsatisfying. Amid growing strife—including incidents of alleged infidelity and separation—the respondent consulted a clinical psychologist, Dr. Elena A. Del Rosario. Based on her evaluation, he was diagnosed with a Passive-Aggressive Personality Disorder characterized by covert obstructionism, impulsivity, complaints of being misunderstood, and a need for additional care (evidenced by courting another woman). Dr. Del Rosario opined that this personality disorder was serious, permanent, incurable, and predated the marriage, thereby interfering with his capacity to fulfill marital obligations. Relying on these findings and his own testimony, respondent filed a petition for declaration of nullity of marriage under Article 36 of the Family Code, alleging psychological incapacity. The lower courts—first the Regional Trial Court and then the Court of Appeals—found in his favor, declaring the marriage void ab initio, though Haydee and other evidence suggested that the couple had maintained essentially normal and, at times, reconciled relations through the years.Issues:
Whether there was sufficient and clear and convincing evidence to establish that respondent suffered from a grave, permanent, incurable psychological incapacity—which preexisted or attached at the time of the marriage—that rendered him unable to comply with the essential marital obligations, thus justifying a declaration of nullity of marriage under Article 36 of the Family Code.Ruling:
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Ratio:
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Doctrine:
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