G.R. No. 168328 - Republic vs. Tanyag-San Jose

Laila Tanyag-San Jose and Manolito San Jose were married on June 12, 1988.
At the time of the marriage, Laila was 19 years and 4 months old and Manolito was 20 years and 10 months old.
The couple had two children: Joana Marie (born January 3, 1989) and Norman (born March 14, 1997).
For several years, they resided with Manolito’s parents, during which Manolito was jobless, engaged in gambling and drug-related activities, while Laila supported the family by selling fish at a wet market.

Manolito’s persistent irresponsibility, involvement in vices (gambling, drugs, excessive drinking), and lack of support led to ongoing marital strife.
Laila, as the family breadwinner, bore the burden of financial and emotional responsibilities.
The situation deteriorated to the point where Laila separated from Manolito on August 20, 1998 when he failed to return from his late-night outings.

On March 9, 1999, Laila filed a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code, contending that Manolito was psychologically incapacitated to perform marital obligations.
In the petition, Laila claimed that Manolito’s behavior, including his irresponsibility, drug use, refusal to work, and general neglect of his marital duties, evidenced psychological incapacity.
Dr. Nedy Tayag, a clinical psychologist, submitted a report stating that based on her clinical interview and psychological tests on Laila (and not on a direct evaluation of Manolito), she concluded that Manolito suffered from Anti-Social Personality Disorder, which rendered him incapable of fulfilling his marital roles.

The Regional Trial Court (RTC) of Pasig initially denied Laila’s petition on July 17, 2001, citing precedents (Republic of the Philippines v. Court of Appeals and Leouel Santos v. CA) which emphasized that psychological incapacity must be grave, have juridical antecedence, and be incurable.
Laila’s subsequent motion for reconsideration of the RTC decision was also denied on November 13, 2001.
The Court of Appeals later reversed the RTC decision on February 15, 2005, finding that the totality of the evidence supported the conclusion that Manolito was psychologically incapacitated, and declared the marriage void ab initio.
The Republic of the Philippines, as petitioner in the review, challenged the appellate court’s findings, contending both procedural and substantive deficiencies in proving psychological incapacity.

Whether Laila established that Manolito’s alleged behavioral defects amount to psychological incapacity under Article 36 of the Family Code.

Was the evidence presented sufficient to prove a grave psychological disorder that existed at or before the marriage?
Did the evidence satisfy the criteria of juridical antecedence, gravity, and incurability as mandated by judicial precedents?

The admissibility and reliability of the psychological evaluation conducted by Dr. Nedy Tayag.

Can a psychological report based solely on the petitioner’s account (without direct examination of the respondent) be considered reliable evidence of psychological incapacity?
Does relying on hearsay information through the expert’s assessment meet the required threshold to establish a psychological diagnosis?

Whether deviating from or strictly adhering to the Molina guidelines and the doctrine of stare decisis was appropriate in the circumstances of the case.

Is it proper for the appellate court to diverge from the established parameters set by the Molina case given the present facts?
Did the evidence justify a deviation from the precedent which requires concrete, demonstrable evidence of psychological incapacity?

Whether behavioral deficiencies (such as irresponsibility, drug use, and gambling) without clear surgical correlation to a psychological disorder are sufficient grounds for the nullity of marriage.