G.R. No. 4750 - People vs Gutierrez

On February 27, 2007, Maria Concepcion N. Singson (a.k.a. Concepcion N. Singson) filed a petition for declaration of nullity of marriage under Article 36 of the Family Code.
The petition alleged that her marriage to Benjamin L. Singson on July 6, 1974, was vitiated by respondent’s psychological incapacity.
Allegations included respondent’s alleged personality disorder characterized by pathological gambling, infidelity, irresponsibility, and a fundamental inability to provide support and perform marital obligations.

The marriage, solemnized at St. Francis Church in Mandaluyong, Rizal, produced four children, all of legal age at the time of the petition.
Petitioner described respondent as having displayed a pattern of abnormal behavior—dishonesty, extravagance, immaturity, and inability to discharge paternal obligations—stemming from his compulsive gambling and alleged personality disorder.
It was alleged that respondent’s psychological issues had roots in his early life, including a dysfunctional family environment and emotional neglect regarding sibling favoritism.

Petitioner presented several pieces of documentary evidence including the marriage contract, birth certificates, judicial affidavits, and notably, the clinical summary and judicial affidavit of Dr. Benita Sta. Ana-Ponio, who diagnosed respondent with pathological gambling and a personality disorder.
The expert’s findings highlighted:

Preoccupation with gambling and behaviors such as stealing and pawning belongings.
A need for increasing sums to achieve the desired gambling effect.
A longstanding maladaptive pattern that impeded respondent’s ability to discharge marital duties.

The claim of “psychological incapacity” was unsupported by facts and evidence.
He was capable of rendering support and performed essential marital and familial duties, including providing financial support, a family home, and maintaining employment.

He also argued that his alleged behavior, including instances of confinement for treatment, did not equate to a grave or incurable psychological disorder.

The RTC conducted pre-trial hearings and admitted the evidence submitted by petitioner.
During the trial, petitioner’s witnesses, including herself, her son, and Dr. Sta. Ana-Ponio, testified to the respondent’s incapacity.
On November 12, 2010, the RTC declared the marriage void ab initio on the ground of respondent’s psychological incapacity, emphasizing that the evidence established a grave, incurable, and juridically antecedent personality disorder.
Respondent’s subsequent motion for reconsideration was denied, and he filed a Notice of Appeal.

In its August 29, 2013 Decision, the Court of Appeals reversed the RTC ruling.
The CA held that the evidence did not prove that respondent’s psychological incapacity was grave, serious, or incurable at the time of the marriage.
The appellate court underscored that any doubts must favor the continuation and validity of the marriage, given its constitutional and statutory protection.

Petitioner moved for reconsideration of the CA decision, which was denied on January 6, 2014.
The resultant final disposition was the dismissal of the petition for nullity, thereby affirming the validity of the marriage.

Whether the Court of Appeals erred in reversing the Regional Trial Court’s decision declaring the marriage null for psychological incapacity.

Whether the evidence presented established that respondent’s alleged psychological incapacity was:

Grave and serious enough to render him incapable of performing essential marital obligations.
Incurable or permanent in nature.
Present at the time of the marriage (juridical antecedence).

Whether the findings of the expert, Dr. Sta. Ana-Ponio, supported the petitioner's claims beyond mere characterizations of unfavorable personality traits.