Case Summary (G.R. No. 161422)
Procedural History
Petitioner filed for annulment in the RTC on grounds of respondent’s psychological incapacity. Respondent defaulted; OCP investigated collusion and recommended trial on the merits. A clinical psychologist evaluated both spouses. RTC declared the marriage void for mutual psychological incapacity. OSG appealed. CA reversed, finding lack of direct examination of respondent and failure to meet Molina requirements. SC entertained petitioner’s petition under Rule 45.
Issue on Review
Whether, under Article 36 of the Family Code and the 1987 Constitution, the parties’ marriage is void ab initio by reason of psychological incapacity.
Supreme Court Analysis and Applicable Standards
- Article 36 contemplates a party’s inability, from psychological causes, to assume essential marital obligations (Articles 68–71: cohabitation, love, respect, fidelity, help, and support).
- The 1987 Constitution declares marriage inviolable and mandates state protection for the family, imposing a high threshold for dissolution.
- Molina guidelines require the root psychological cause (a) be alleged, (b) clinically identified, (c) proven by experts, and (d) clearly explained; show inception at celebration; manifest permanent or relative incurability; be grave enough to disable marital obligations; and specify the breached obligations.
- Expert opinions, even if based on collateral data, are decisive when they demonstrate a causal link between a diagnosed disorder and incapacity to discharge marital duties.
Psychological Capacity Assessment
The clinical psychologist administered multiple projective and objective tests (MMPI, Rorschach, Bender, etc.) and life-history interviews. Findings:
– Petitioner exhibits dependent personality disorder (inability to make independent decisions, fear of abandonment, submissiveness).
– Respondent exhibits narcissistic and antisocial personality disorders (exploitative behavior, disregard for rights of others, impulsivity, intimidation).
Supreme Court Ruling
Both parties were found psychologically incapacitated to assume essential marital obliga
...continue readingCase Syllabus (G.R. No. 161422)
Facts of the Case
- Petitioner Edward Kenneth Ngo Te (29 at evaluation) and respondent Rowena Ong Gutierrez Yu-Te (20 at marriage) met through a college Filipino-Chinese association in January 1996.
- Three months later, at respondent’s insistence, they eloped to Cebu, ran out of funds in a month, and returned to Manila.
- Facing respondent’s suicidal threats, petitioner agreed to marry her; they wed on April 23, 1996 at Valenzuela through respondent’s uncle, without a marriage license.
- After marriage, petitioner was confined in respondent’s uncle’s house, threatened with firearms and blackmail; he eventually escaped after one month.
- Despite familial support, respondent refused reconciliation unless petitioner accessed his inheritance; upon learning he was disinherited and jobless, she ceased contact and they separated in June 1996.
Procedural History
- January 18, 2000: RTC Quezon City, Branch 106, Civil Case No. Q-00-39720, petitioner filed for nullity of marriage on psychological incapacity grounds.
- July 2000: RTC ordered OCP to investigate collusion; OSG deputized OCP for hearings.
- August 2000: OCP recommended trial on merits.
- July 30, 2001: RTC rendered decision declaring marriage null and void for psychological incapacity of both parties.
- Republic of the Philippines (OSG) appealed to Court of Appeals (CA).
- August 5, 2003: CA reversed RTC, declaring marriage valid—finding no proof of respondent’s incapacity, lack of OSG certification, and non-compliance with Molina guidelines.
- January 19, 2004: CA denied petitioner’s motion for reconsideration.
- June 15, 2005: Supreme Court (SC) gave due course to petitioner’s Rule 45 certiorari petition.
Psychological Evaluation and Expert Findings
- Clinical psychologist evaluated both spouses using multiple instruments (Rorschach, MMPI, Bender-Gestalt, etc.) and life-history interviews.
- Petitioner diagnosed with Dependent Personality Disorder:
• Excessive dependence on others for decisions, fear of abandonment, helplessness when alone, submissive to demands.