Case Summary (G.R. No. 73271)
Factual and Procedural Background
Angelique and Mark's relationship began in high school, marked by volatility, jealousy, infidelity, and physical violence. They experienced numerous breakups and reconciliations over five years as partners before marrying due to an unplanned pregnancy. Their married life was similarly troubled, continuing with physical abuse, deception, and irresponsibility, especially on Mark's part. Angelique sought nullity of marriage on the basis of both spouses’ psychological incapacity. The trial court granted the petition, finding both parties psychologically incapacitated. The Court of Appeals affirmed, and the Republic, through the Office of the Solicitor General (OSG), petitioned for certiorari to overturn these rulings.
Psychological Capacity and Expert Testimony
Angelique’s diagnosis of borderline personality disorder and Mark’s narcissistic personality disorder were established through psychiatric evaluation by Dr. Jay Madelon Castillo-Carcereny. The psychiatrist based her findings on clinical interviews, psychological testing, and collateral information from Angelique and her father. Despite not personally examining Mark, the expert’s opinion was admitted as it relied on facts reasonably relied upon in psychiatric practice, in line with the ruling in Tan-Andal v. Andal. The disorders manifested severe emotional instability, interpersonal dysfunction, impaired judgment, aggressive and abusive behavior—conditions that predated the marriage and continued to worsen.
Legal Framework: Article 36 of the Family Code and Psychological Incapacity
Article 36 provides that a marriage is void when at least one party is psychologically incapacitated to fulfill essential marital obligations at the time of marriage, even if the incapacity becomes apparent only later. The Supreme Court clarified in Tan-Andal v. Andal that psychological incapacity is a legal concept, not strictly medical; thus, clinical diagnosis is not mandatory. Key criteria include juridical antecedence (existence prior to marriage), gravity (incapacity is serious, not mere personality quirks or mood swings), and incurability (legal, not medical, implying irreparable incompatibility). The burden is on the petitioner to prove psychological incapacity by clear and convincing evidence, meaning evidence more substantial than preponderance but less than beyond reasonable doubt.
Evaluation of Evidence and Credibility
The Court upheld the findings of the trial court and Court of Appeals emphasizing the credibility of Angelique’s testimony, witness Johnson’s corroboration, and expert psychiatric evaluation. The courts gave weight to the totality of behaviors showing deep-seated psychological dysfunctions manifesting throughout the couple’s relationship. The prolonged history of violence, distrust, infidelity, manipulation, and emotional instability demonstrated the parties’ utter inability and unwillingness to discharge the essential duties of spousehood — mutual love, respect, fidelity, and support as prescribed in Article 68 of the Family Code.
Distinction from Grounds for Legal Separation
While acts of infidelity, physical abuse, neglect, and abandonment are grounds for legal separation, the Court found that when these conduct patterns reflect the presence of grave and permanent psychological incapacity that preexisted marriage, a declaration of nullity is warranted. Here, the couple’s combined psychological impairments created a dysfunctional, loveless marital environment from the outset, rendering the marriage void ab initio.
Reliability and Admissibility of Expert Opinion
In accordance with Tan-Andal, the Court emphasized that expert opinion need not be based solely on direct clinical examination to be admissible. Psychiatric diagnoses may also rest reasonably on well-founded collateral information and standardized psychological tests, which Dr. Castillo-Carcereny duly employed. The State did not effectively challenge the psychiatrist’s expertise or m
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Facts of the Case
- Angelique Pearl O. Claur petitioned for the declaration of nullity of her marriage with Mark A. Claur on the ground of psychological incapacity of both spouses.
- They began as high school classmates with Angelique Pearl having a crush on Mark, who had a notorious reputation for flirtation and early drinking.
- Their courtship was marked by Mark’s obsessive jealousy, frequent infidelity, deception, and unstable behavior, while Angelique Pearl threatened self-harm to prevent breakups.
- The relationship was characterized by alternating breakups and reconciliations about twenty times over five years, with escalating fights including physical violence.
- They married on January 3, 2009, after Angelique Pearl’s unexpected pregnancy and under the insistence of Mark and his parents, who promised relocation to the United States.
- After marriage, the couple lived in difficult circumstances, with revelations of Mark’s lies regarding his education and family’s financial status, his reliance on Angelique Pearl for monetary support, frequent quarrels, physical violence, and eventual separation.
- Their son was born on April 4, 2009.
- Both spouses inflicted physical injuries on each other during incidents of conflict, including Mark’s broken jaw and a head laceration.
- Mark exhibited laziness, extravagance, vices, and failure to seek employment despite having completed college.
- The couple lived separately from January 2012 onwards following a final separation.
Testimonies and Expert Findings
- Angelique Pearl gave detailed testimony of their troubled relationship, highlighting Mark’s jealousy, infidelity, dishonesty, violent behavior, and neglect of familial responsibilities along with her own emotional struggles.
- Johnson C. Tiu, Angelique Pearl’s uncle and confidant, corroborated her account of their turbulent relationship, Mark’s continued philandering, and physical abuse including the broken jaw incident.
- Dr. Jay Madelon Castillo-Carcereny, a psychiatrist, personally examined Angelique Pearl and interviewed her father but did not examine Mark personally.
- Dr. Castillo-Carcereny diagnosed Angelique Pearl with borderline personality disorder, identifying traits such as frantic efforts to avoid abandonment, unstable relationships, impulsivity, suicidal behavior, mood instability, chronic emptiness, and intense anger.
- Based on interviews and information from Angelique Pearl and her father about Mark's behavior, Dr. Castillo-Carcereny diagnosed Mark with narcissistic personality disorder, characterized by grandiosity, fantasies of success, need for admiration, entitlement, exploitative behavior, lack of empathy, and arrogance.
- The psychiatrist explained that the personality disorders stemmed from dysfunctional family backgrounds and were grave, permanent, and incurable.
- She recommended the annulment of marriage on the ground of psychological incapacity manifesting from early adulthood.