CASE DIGEST
Georfo vs. Republic
(G.R. No. 246933, March 6, 2023)
SECOND DIVISION, LEONEN J.
Psychological incapacity is a legal concept, not an illness which has to be medically or clinically identified.
Agnes and Joe-Ar got married after a brief courtship and had a son. Their marriage quickly deteriorated due to conflict, infidelity, and abuse. Agnes filed for the nullity of their marriage, claiming Joe-Ar's psychological incapacity. Dr. Gerong, a clinical psychologist, provided an expert opinion, citing Joe-Ar's narcissistic personality disorder and other issues as causes of incapacity. Joe-Ar’s sister also testify regarding his abusive behavior, as she once saw how Joe-ar and his family mistreated Agnes.
Was there sufficient evidence to prove Joe-Ar's psychological incapacity as the basis for the nullity of the marriage?
YES. In proving psychological incapacity doesn't necessitate a psychiatric examination and that it's based on legal standards, not medical diagnoses. The totality of evidence, including expert opinions, testimonies, and behavior patterns, can establish psychological incapacity. The court ruled that Agnes had successfully proven Joe-Ar's psychological incapacity. Dr. Gerong's psychological assessment, based on testimonies from Agnes and her sister, supported this claim. The court emphasized that psychological incapacity is a legal concept, not a specific illness, and psychiatric evaluation is no longer a requirement. Therefore, their marriage was declared void under Article 36 of the Family Code.
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