CASE DIGEST
Quiogue, Jr. v. Quiogue
G.R. No. 203992,
[August 22, 2022]
SECOND DIVISION, LOPEZ, M.
Persons and Family Relations; Marriages; Psychological Incapacity; Chronic Infidelity
Psychological incapacity is determined
by clear acts of dysfunctionality that undermine the marital union, and it need
not be medically diagnosed. Chronic infidelity is a manifestation of
psychological incapacity.
Antonio S. Quiogue, Jr. filed a
Petition for Declaration of Nullity of Marriage against his wife, Maria Bel B.
Quiogue (Maribel). They were married on October 16, 1980, and have four
children. They separated in 1998 after Maribel drove Antonio out of their
conjugal home due to his infidelity. Antonio claimed that both he and Maribel
were psychologically incapacitated to fulfill their marital obligations.
Maribel denied driving Antonio out and accused him of chronic womanizing,
nocturnal gambling, and abusive behavior. After referral to the public
prosecutor and failed attempts at reconciliation, the case proceeded to trial.
Whether the marriage between Antonio
and Maribel should be declared null and void based on the ground of
psychological incapacity.
YES. The court ruled in favor of Antonio, declaring the
marriage null and void due to his psychological incapacity. The court clarified
that psychological incapacity, as defined under Article 36 of the Family Code,
requires the presence of gravity, juridical antecedence, and incurability. It
emphasized that psychological incapacity need not be medically diagnosed, and
the assessment can be based on the totality of evidence.
Antonio's chronic infidelity was considered a manifestation of his psychological incapacity. His behavior, deeply rooted in his upbringing and personality structure, indicated his inability to maintain monogamous relationships and his distorted understanding of marital obligations. Antonio's inability to maintain a faithful and committed relationship with Maribel was rooted in a dysfunctional personality structure that preexisted their marriage. Antonio's lack of genuine remorse and unwillingness to change further supported his psychological incapacity.
Maribel's retaliatory acts and evicting Antonio from the conjugal home, were deemed a reaction to Antonio's philandering and not a basis for psychological incapacity. Admittedly, Maribel's vengeful stance contributed to the collapse of the marriage as it aggravated Antonio's psychological incapacity. Despite Maribel's belligerent attitude and verbal offensives towards Antonio, the Court rules that these do not amount to psychological incapacity.
Thus, the court concluded that
Antonio's psychological incapacity rendered the marriage null and void.
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