Case Summary (G.R. No. 247583)
Facts
• Courtship and Marriage: Introduced in August 1998, the parties married on July 18, 2000 at Talavera Municipal Hall, Nueva Ecija, and had three children. They lived in respondent’s parents’ house in Calipahan, Talavera.
• Alleged Misconduct: Petitioner alleged that respondent refused sexual relations without cause, demanded solitude, engaged in constant nagging, unfounded jealousy, verbal abuse, and repeatedly drove him out of the home. Separation ensued in 2008.
• Expert Assessment: Petitioner’s psychologist, Dr. Pacita Tudla, diagnosed respondent with Histrionic and Paranoid Personality Disorders based solely on interviews with petitioner, their driver, and a neighbor. Respondent did not submit to evaluation.
Procedural History
• July 28, 2010: Petition for nullity under Article 36, Family Code, docketed as Civil Case No. SD (10)-786, RTC-Branch 88.
• June 30, 2017: RTC denied nullity petition for lack of proof of psychological incapacity. Motion for new trial, seeking to add a childhood friend’s testimony, was likewise denied.
• April 26, 2019: Court of Appeals (CA) affirmed, finding one-sided and insufficient evidence.
• October 6, 2021: Supreme Court docketed petitioner’s Rule 45 petition for review.
Applicable Law
• 1987 Constitution.
• Family Code of 1987 (as amended)
– Article 36: Marriage is void if a party was psychologically incapacitated at solemnization.
– Article 68: Mutual obligations to live together, love, respect, fidelity, help, and support.
• Presumption in favor of marriage validity; burden of proof by clear and convincing evidence (Tan-Andal v. Andal, G.R. No. 196359, May 11, 2021).
• Psychological incapacity: durable personality structure manifested by clear acts of dysfunctionality; expert opinion not required but may be considered.
Issue
Did petitioner prove, by clear and convincing evidence, that respondent was psychologically incapacitated at the time of marriage, rendering compliance with essential marital obligations impossible?
Legal Standards and Ruling
The petition is DENIED. Psychological incapacity under Article 36 requires proof of:
- Juridical antecedence – existence of incapacity at solemnization.
- Gravity – incapacity must be so serious and enduring that essential marital obligations cannot be discharged.
- Incurability – legal permanency of the incapacity.
Proof must overcome the presumption pro matrimonio by clear and convincing evidence. Expert opinion is unnecessary; lay testimony on observable dysfunctional acts may suffice.
Application of Standards to Evidence
• Petitioner’s and collateral witnesses’ general allegations of suspicion, jealousy, verbal outbursts, and ejection from the home fail to explain the underlying causes or demonstrate a true personality structure that makes marital obligations impossible.
• Respondent’s conduct could be normal reactions to alleged infidelity rather than manifestations of an incurable psychic disorder.
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Case Syllabus (G.R. No. 247583)
Facts of the Case
- In August 1998, a mutual friend introduced Rommel M. Espiritu (petitioner) to Shirley Ann Boac-Espiritu (respondent); one month later they became lovers.
- They married on July 18, 2000 at the Municipal Hall of Talavera, Nueva Ecija, officiated by Mayor Manolito Fausto, and had three children.
- The couple lived in a house owned by respondent’s parents in Calipahan, Talavera, Nueva Ecija.
- Petitioner, a police officer assigned away from home, could only return weekly; respondent reacted with hostility on his return:
- Refused marital relations and suggested he seek another woman.
- Demanded to sleep separately and be left alone.
- Picked quarrels over trivial matters, cursed at him, and called him a worthless husband.
- Suspected him of infidelity: sniffed his clothes, checked his cellphone, wallet, and ATM transactions.
- Acted hot-tempered, jealous, and distrustful, comparing him to her father who abandoned the family.
- Respondent prioritized friends over family, leaving their children unattended, and on several occasions drove petitioner out of the home.
- The couple effectively separated in 2008; petitioner then consulted clinical psychologist Dr. Pacita Tudla.
Expert Report by Dr. Pacita Tudla
- Dr. Tudla interviewed petitioner, their driver (Rolando David), and neighbor (Ricardo Maligaya); respondent ignored the invitation to be interviewed.
- Based on available information, Dr. Tudla diagnosed respondent with:
- Histrionic Personality Disorder characterized by excessive emotionality, attention-seeking, selfishness, unreliability, overreactions, suggestibility, and lack of analytic ability.
- Paranoid Personality Disorder characterized by pervasive distrust, unfounded accusations, unreasonable jealousy, and resentfulness.
- Dr. Tudla traced these personality disorders to respondent’s childhood trauma:
- Father’s abandonment and financial neglect.
- Mother’s absence due to work abroad.
- Lenient grandparents who fostered a carefree, undisciplined upbringing.
- Concluded that respondent’s personality st