Case Summary (G.R. No. 210766)
Factual Antecedents
On February 27, 2007, the petitioner filed a Petition for Declaration of Nullity of Marriage against the respondent based on alleged psychological incapacity under Article 36 of the Family Code. The petition claimed substantial evidence of the respondent's inability to perform marital obligations due to various psychological issues, including pathological gambling and personality disorders, presenting a diagnosis from Dr. Benita Sta. Ana-Ponio indicating that the respondent engaged in harmful behaviors such as lying, gambling, and engaging in illegal acts to support his addiction. Furthermore, it was claimed that these issues rendered the respondent incapable of performing his responsibilities as a husband and father.
Respondent’s Position
In response, the respondent denied the allegations, arguing that the claims of psychological incapacity were unsupported and did not meet the legal criteria of being grave, incurable, and having juridical antecedence. He maintained that he was capable of fulfilling his marital obligations and highlighted that he had a college degree, was employed in a banking job, and owned properties, thus disputing the assertion that he had psychological issues that impaired his capacity to perform marital duties.
Ruling of the Regional Trial Court
The RTC, after trial, granted the petition and declared the marriage void ab initio based on findings of psychological incapacity. The court justified its decision by acknowledging the respondent's psychological condition as grave and incurable, emphasizing the detriments caused by his personality disorder. The RTC authority based its ruling on evidence that supported the existence of psychological incapacity that stemmed from the respondent’s gambling behavior and identified a lack of capacity to perform marital obligations as outlined in the Family Code.
Ruling of the Court of Appeals
The Court of Appeals reversed the RTC decision, emphasizing that the petitioner failed to provide compelling evidence that demonstrated the respondent's psychological incapacity was serious, incurable, and existed at the time of marriage. The CA critiqued the reliance on the psychiatric report, asserting that mere difficulties in marital performance do not equate to legal psychological incapacity as defined by jurisprudence. The court clarified that the petitioner did not discharge the burden of proof required to declare the marriage null and void.
Issues Raised by the Petitioner
The petitioner subsequently challenged the CA's ruling, asserting that the evidence presented confirmed that the respondent suffered from psychological incapacity, including its antecedence, gravity, and incurability. Specifically, she referred to expert testimony and corroborating evidence regarding the respondent's inability to fulfill basic marital duties, arguing that this incapacity predated the marriage.
Respondent’s Arguments on Appeal
The respondent argued for affirmation of the CA's decision, claiming that the evidentiary basis presented by the petitioner throughout the various proceedings did not convincingly establish his psychological incapacity. He asserted that the trial and appellate courts had adequately assessed the evidence and found it insufficient to justify a declaration of nulli
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Case Overview
- The case is a Petition for Review on Certiorari concerning the marriage nullity of Maria Concepcion N. Singson and Benjamin L. Singson.
- The Supreme Court reviewed the Court of Appeals' decision which overturned the Regional Trial Court's declaration of nullity based on psychological incapacity.
- The central issue revolved around the interpretation and application of Article 36 of the Family Code regarding psychological incapacity.
Factual Antecedents
- On February 27, 2007, Maria Concepcion N. Singson filed a Petition for declaration of nullity of marriage based on Article 36 of the Family Code.
- The couple married on July 6, 1974, and had four children, all of legal age at the time of the petition.
- Petitioner outlined numerous allegations against respondent including dishonesty, irresponsibility, infidelity, and compulsive gambling.
- Respondent was diagnosed with Pathological Gambling and Personality Disorder by Dr. Benita Sta. Ana-Ponio, which affected his ability to fulfill marital obligations.
Respondent's Answer
- Respondent denied the allegations, arguing that psychological incapacity must be grave, juridical in nature, and incurable.
- He countered that his failures were not psychological disorders but mere shortcomings in his role as a husband.
- Respondent claimed there were conjugal assets and debts, contrary to the petitioner's claims.
Trial Court's Ruling
- The Regional Trial Court (RTC) ruled in favor of the petitioner on November 12, 2010, declaring the marria