Case Summary (G.R. No. 196359)
Separation and Custody Dispute
By 2000, respondent’s persistent irresponsibility and substance abuse prompted separation. Mario sought joint custody in December 2001; Rosanna continued sole custody of Samantha.
Nullity Petition and Consolidation
In August 2003, Rosanna petitioned to void the marriage for respondent’s alleged psychological incapacity. The trial court consolidated this with the custody case, ordered a prosecutor’s report, and found no collusion.
Allegations of Psychological Incapacity
Rosanna testified that Mario frequently disappeared for days, mismanaged finances, proved emotionally erratic and abusive, and exposed Samantha to drug use. His heavy marijuana and shabu habits persisted despite promises to quit. He also demonstrated paranoia and refusal to support his family.
Expert Evaluation of Respondent’s Mental Condition
Dr. Valentina Del Fonso Garcia, psychiatrist, interviewed Rosanna, Samantha, and Rosanna’s sister and reviewed documents— including Mario’s own handwritten history from rehabilitation. She diagnosed him with narcissistic-antisocial personality disorder and substance abuse disorder with psychotic features, finding the disorders grave, deeply rooted, and medically incurable.
Respondent’s Counterclaim
Mario contended that Rosanna was the psychologically incapacitated spouse, alleging violence and instability on her part, and sought nullity in his favor plus equal property division and custody of Samantha.
Trial Court Ruling
On May 9, 2007, the RTC found Rosanna proved Mario’s psychological incapacity by clear evidence of his enduring disregard for marital duties, substance abuse, and incapacity to support and care for his family. Marriage was declared void ab initio, custody awarded to Rosanna, and the Parañaque duplex with its lot granted to her exclusively.
Court of Appeals Reversal
The CA reversed on February 25, 2010, ruling Dr. Garcia’s evaluation “unscientific and unreliable” because she did not personally interview Mario. It also held the trial court failed to base its property award on clearly stated facts and law.
Issues Before the Supreme Court
- Whether the marriage is void due to respondent’s psychological incapacity.
- The validity of the Molina guidelines (from Republic v. Court of Appeals and Molina) on psychological incapacity under Article 36.
- Proper property regime for the Parañaque duplex and lot.
- Rightful custody of Samantha.
Legal Framework for Psychological Incapacity
Article 36 declares void marriages of parties who, at celebration, were psychologically incapacitated to comply with essential marital obligations—living together, love, respect, fidelity, help, and support—even if such incapacity manifests later.
Supreme Court’s Restatement of Doctrine
• Quantum of Proof: Petitioner must prove psychological incapacity by clear and convincing evidence, reflecting the State’s constitutional mandate to protect marriage as an inviolable social institution.
• Psychological Incapacity as Legal Concept: Not strictly a medical diagnosis or personality disorder; it encompasses any durable psychological condition or personality structure that prevents compliance with essential marital duties.
• Expert Opinion: Not indispensable; evidence may include ordinary witnesses’ testimony. Expert reports remain persuasive but courts assess the totality of evidence.
• Juridical Antecedence: Incapacity must have existed at time of marriage celebration.
• Gravity: Acts or omissions must go beyond refusal, neglect, or difficulty—mild character quirks are excluded.
• Incapacity as Legally Incurable: A permanent inability relative to the specific spouse, not necessarily a medically uncurable illness.
Application to the Parties’ Case
Applying these restated principles, the Supreme Court found the trial court’s findings supported by clear and convincing evidence
...continue readingCase Syllabus (G.R. No. 196359)
Facts
- Rosanna L. Tan (Rosanna) married Mario Victor M. Andal (Mario) on December 16, 1995 in Makati City
- Their only child, Ma. Samantha, was born July 27, 1996
- Mario displayed erratic behavior: secretive night-outs, financial irresponsibility, threats
- He developed paranoia, drug addiction (marijuana, shabu), and grandiose, antisocial traits
- Despite repeated rehabilitation attempts, Mario relapsed; Rosanna bore sole responsibility for their daughter
- The couple separated in 2000; Rosanna retained custody of Samantha
Procedural History
- July 2003: Rosanna filed petition for nullity of marriage (psychological incapacity) in RTC Parañaque
- Feb. 2004: Prosecutor reported no collusion between spouses; cases consolidated
- May 9, 2007: RTC declared marriage void ab initio (Art. 36 FC), awarded Rosanna custody and sole ownership of Parañaque duplex and lot
- Feb. 25, 2010: Court of Appeals reversed RTC, held marriage valid; dismissed expert’s evaluation
- May 11, 2021: Supreme Court granted petition for review; reversed CA; reinstated RTC Decision
Issues
- Whether the marriage is void ab initio under Art. 36 (psychological incapacity)
- Whether the Molina guidelines unduly restrict Art. 36’s application
- Whether psychological incapacity requires medical/clinical diagnosis, permanence, and antecedence
- Proper division of the Parañaque duplex and lot
- Appropriateness of awarding custody to Rosanna
Parties’ Contentions
- Rosanna: Mario’s substance abuse, irresponsibility, irritability, neglect and threats evidence a grave, enduring, antecedent incapacity. Expert Dr. Garcia diagnosed Narcissistic Antisocial Personality Disorder with psychotic features. Psychological incapacity proven by totality of evidence; expert need not personally examine respondent.
- Mario: Denied enduring incapacity; claimed petitioner was violent, domineering, and mentally unfit. Argued that his past drug use at most supports legal separation, not voiding marriage. Maintained no personality disorder clinically identified in due course.
Trial Court Findings
- Admitted Dr. Garcia’s p