CASE DIGEST
Dedicatoria v.
Dedicatoria
G.R. No. 250618, [July 20, 2022]
SECOND DIVISION , LOPEZ, M.V.
Persons and Family Relations; Marriages; Psychological Incapacity
Psychological incapacity as a ground to
consider a marriage void under Article 36 of the Family Code, is not a medical,
but a legal concept. It is neither a mental incapacity nor a personality disorder in a strict
medical sense, although one's clinical mental or personality disorder can be
its root cause. Psychological incapacity should be assessed based on clear and
convincing evidence rather than rigid medical criteria.
Jennifer and Ferdinand got married in
1995. Jennifer later filed for nullity of their marriage, claiming that Ferdinand's
psychological incapacity caused their marriage to fail. During trial, Jennifer
testified that she noticed how irresponsible, immature, insensitive, self-centred,
and dependent on his parents Ferdinand was. Despite their marriage, Ferdinand
continued to reside with his parents, who provided for his needs, rendering him
jobless and reliant on them. She also presented testimonies from witnesses and
a clinical psychologist's evaluation, which diagnosed Ferdinand with Dependent
Personality Disorder. This disorder made him immature, irresponsible, and
unable to fulfill his marital duties rooted in his upbringing, primarily
characterized by overdependence on his parents and a lack of personal
responsibility.
Whether there is enough evidence to
prove Ferdinand's psychological incapacity as grounds to void the marriage
under Article 36 of the Family Code.
YES. The court ruled in favor of Jennifer, declaring the marriage null and void. Supreme Court held that psychological incapacity is a legal concept and does not necessarily require a clinical diagnosis. Its existence does not demand strict medical criteria but relies on clear and convincing evidence. The court rejected the notion that both spouses need to be examined by a psychologist for the diagnosis to be reliable. Instead, psychological incapacity should be assessed based on the totality of clear and convincing evidence rather than rigid medical criteria. Such that expert opinions furnished by psychiatrists or psychologists on the psychological temperament of parties are not indispensable.
The evidence from Jennifer's testimony, corroborated by her friend Anarose and the expert psychologist, showed that Ferdinand's personality traits and behaviors rendered him unable to fulfill his marital obligations. Ferdinand's overdependence on his parents, lack of employment, and failure to assume responsibilities within the marriage were key indicators of his psychological incapacity. The court acknowledged these traits as deep-rooted and irreparable, leading to marriage breakdown. The court stressed that psychological incapacity is not about medical conditions but rather to an individual's inability to comprehend and fulfill essential marital obligations caused by dysfunctionality in a person's personality structure.
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