Case Summary (G.R. No. 253342)
Background of the Case
The genesis of this case traces back to February 20, 2014, when Dionisio filed a petition for a declaration of nullity of his marriage with Aurora, citing psychological incapacity. The Regional Trial Court (RTC) in La Trinidad, Benguet, first heard the case but denied the petition. Subsequently, Dionisio's appeal to the Court of Appeals was also denied, propelling him to the Supreme Court for a review via a petition for certiorari.
Psychological Evaluations
Dionisio sought the expertise of Dr. Clarette Rosario Dy, a psychiatrist, who evaluated both spouses. His diagnosis revealed that he suffered from obsessive-compulsive personality disorder, while Aurora was diagnosed with histrionic personality disorder. Dr. Dy asserted that their respective dysfunctions impaired their capacities to fulfill marital obligations.
Trial Court's Decision
The RTC ruled against Dionisio, finding insufficient evidence to establish the psychological incapacities claimed. It highlighted that Dionisio's behaviors, characterized by perfectionism and rigidity, as well as Aurora's alleged irresponsibility, did not equate to psychological incapacity. The court believed that the parties’ difficulties were not grave enough to warrant the nullification of their marriage.
Court of Appeals’ Ruling
Upon appeal, the Court of Appeals affirmed the RTC’s decision, stating that Dionisio had failed to provide compelling evidence of psychological incapacity. The court criticized Dr. Dy’s evaluation for lack of substantive proof regarding the gravity and antecedence of the alleged disorders.
Supreme Court’s Review
In its review, the Supreme Court identified the crux of the matter as whether the marriage should be annulled due to psychological incapacity under Article 36 of the Family Code. The Court referenced the evolving understanding of psychological incapacity, emphasizing that it extends beyond established personality disorders to include mutual incompatibility and antagonistic personality structures.
Legal Framework
The Supreme Court reiterated the concept that psychological incapacity must not only be diagnosed but must also exhibit a persistent lack of capacity to fulfill marital obligations. This incapacity should show a clear, profound disconnect between the spouses, rooted in pre-marital life, rendering the marriage untenable.
Elements of Proof
To establish such incapacity, a petitioner must demonstrate (1) the gra
...continue readingCase Syllabus (G.R. No. 253342)
Background and Procedural History
- Petitioner Dionisio C. Laroco filed a petition for declaration of nullity of marriage against respondent Aurora B. Laroco based on Article 36 of the Family Code, claiming psychological incapacity.
- The petition was filed on February 20, 2014, and docketed as Civil Case No. 14-F-2133 before the RTC Branch 9, La Trinidad, Benguet.
- The RTC denied the petition by decision dated May 22, 2017; petitioner’s motion for reconsideration was also denied.
- The Court of Appeals affirmed the RTC's decision by its November 6, 2019 decision and denied the motion for reconsideration in a resolution dated June 15, 2020.
- Petitioner elevated the case to the Supreme Court via a petition for review on certiorari under Rule 45.
Factual Background and Marriage History
- Petitioner met respondent in 1970 at Saint Louis University, Baguio City; they courted but petitioner broke up due to respondent entertaining other suitors and parental disapproval citing respondent’s reputation for promiscuity and dishonesty.
- Petitioner left for Manila; upon return, respondent revealed pregnancy and forced marriage was arranged by respondent's parents in Lepanto Mines, Benguet in 1971.
- The spouses had three children born between 1972 and 1977.
- Respondent allegedly continued dating other men, mismanaged family finances, borrowed money without repaying, and was implicated in estafa, which petitioner had to address.
- The couple separated; respondent lived with paramour, children suffered maltreatment but later chose to live with petitioner.
Expert Testimony and Psychiatric Evaluation
- Dr. Clarette Rosario Dy, a physician-psychiatrist, evaluated petitioner and respondent.
- Petitioner was diagnosed with Obsessive-Compulsive Personality Disorder characterized by:
- Preoccupation with orderliness, perfectionism, mental and interpersonal control
- Excessive conscientiousness and rigidity
- Psychological incapacity stemming from upbringing and personal history, including inability to reconcile with respondent
- Respondent was diagnosed with Histrionic Personality Disorder characterized by:
- Need for attention, emotional shallowness, dramatization
- Incapacity in sustaining affection and intolerance of frustration
- Both disorders were found grave, permanent, incurable, and existing at the time of marriage, rendering them incapable to fulfill essential marital obligations.
Trial Court’s Findings and Rulings
- The Regional Trial Court denied the nullity petition, ruling:
- Evidence failed to establish psychological incapacity of either spouse at the time of marriage.
- Psychiatric evaluations lacked sufficient proof of gravity, antecedence, or incurability.
- Petitioner’s allegations of respondent’s misco