CASE DIGEST
REPUBLIC V. MA. THERESA RAMORAN-WONG AND VINCENT L. WONG
[G.R. No. 276986, June 17, 2025]
THIRD DIVISION,
SINGH, J.
Family Code;
Psychological Incapacity; Article 36; Molina Guidelines; Collusion;
Psychological Evaluation
A marriage may be declared void ab
initio under Article 36 of the Family Code when the totality of evidence
establishes that one spouse suffers from a grave, juridically antecedent, and
incurable psychological incapacity rendering him or her incapable of performing
the essential obligations of marriage. The Court likewise held that the mere
failure of the respondent spouse to oppose the petition or the participation of
the respondent's relatives as witnesses does not, by itself, establish
collusion. Psychological incapacity must still be proven by clear and
convincing evidence based on the totality of testimonial, documentary, and
expert evidence.
Ma. Theresa Ramoran-Wong (Theresa) and Vincent L. Wong (Vincent) met in 2010 and became romantically involved after Vincent persistently courted Theresa. Even during their courtship, Vincent displayed alarming traits. He lacked ambition, refused to work despite possessing employable skills, frequently demanded money from Theresa to support his vices, exhibited extreme jealousy and possessiveness, stalked her, and threatened suicide whenever Theresa attempted to end their relationship. After Theresa became pregnant, Vincent insisted that she undergo an abortion. Upon the intervention of their respective parents, however, the parties eventually married on 8 March 2012.
The marital relationship rapidly deteriorated. Barely three weeks after the wedding, Vincent disappeared for several days without informing Theresa. Throughout the marriage, he habitually abandoned his family, engaged in excessive drinking, gambling, womanizing, and violent behavior, failed to provide financial support, physically assaulted Theresa, publicly humiliated her, forced her into violent sexual acts, threatened her with a balisong, and openly admitted that he preferred another woman. He likewise neglected their son and eventually cohabited with another woman with whom he fathered an illegitimate child. Theresa ultimately sought employment abroad to support their child because Vincent persistently refused to assume his responsibilities as husband and father.
Unable to endure the continuing abuse, Theresa filed before the Regional Trial Court a Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code on the ground of Vincent's psychological incapacity. During trial, she presented her own testimony, the testimonies of her mother, Vincent's father and cousin, and the expert testimony of clinical psychologist Dr. Gemma Marie Alhama. After conducting psychological examinations and interviews, Dr. Alhama concluded that Vincent suffered from Narcissistic Personality Disorder, Antisocial Personality Disorder, and Histrionic Personality Disorder, all of which were grave, incurable, and deeply rooted in his personality even before the marriage. According to the psychologist, these disorders rendered Vincent incapable of complying with the essential obligations of marriage.
Despite the
expert testimony, the RTC dismissed the petition for insufficiency of evidence,
finding the testimonies exaggerated and holding that Vincent's misconduct
merely reflected moral failings rather than psychological incapacity. On
appeal, however, the Court of Appeals reversed the RTC and declared the
marriage void ab initio, ruling that Theresa had established the requisites of
gravity, juridical antecedence, and incurability through clear and convincing
evidence. The Republic, through the Office of the Solicitor General (OSG),
elevated the case to the Supreme Court, arguing principally that collusion
existed because Vincent failed to oppose the petition and even allowed his
father to testify in Theresa's favor.
Whether or not the Court of Appeals correctly declared the marriage void ab initio on the ground of Vincent's psychological incapacity despite the Republic's claim of collusion.
YES. The Supreme Court denied the Republic's
petition and affirmed the Court of Appeals.
The Court first ruled that collusion was not established. The mere failure of Vincent to file an Answer or actively oppose the petition did not constitute collusion. Likewise, the fact that Vincent's father and relatives testified in support of Theresa did not automatically prove that the parties conspired to secure a declaration of nullity. More importantly, the Provincial Prosecutor had previously conducted the mandatory investigation and officially reported that no collusion existed between the parties. Such official finding enjoys the presumption of regularity absent convincing proof to the contrary.
The Court likewise found that Vincent's psychological incapacity was established by clear and convincing evidence. The Court gave substantial weight to Dr. Alhama's comprehensive psychological evaluation, which diagnosed Vincent with Narcissistic, Antisocial, and Histrionic Personality Disorders. These disorders were shown to have originated long before the marriage, were deeply rooted in Vincent's personality, and manifested consistently before, during, and after the marital union. His chronic irresponsibility, violence, infidelity, substance abuse, emotional detachment, inability to provide support, and complete disregard of his duties as husband and father were not merely instances of refusal or difficulty in performing marital obligations but reflected a genuine psychological incapacity to assume them.
Applying Article 36 of the Family Code and the jurisprudential standards beginning with Republic v. Court of Appeals and Molina, as refined in subsequent cases, the Court held that the requisites of juridical antecedence, gravity, and incurability were sufficiently established. Vincent's psychological disorders existed prior to the marriage, persisted throughout the relationship, and rendered him permanently incapable of fulfilling the essential obligations of marriage. His abusive conduct, emotional abandonment, repeated infidelity, financial irresponsibility, and complete lack of commitment demonstrated that the marriage had irretrievably failed because of his psychological condition rather than mere marital incompatibility or moral deficiency.
The Court concluded that while marriage
remains an inviolable social institution deserving of the State's highest
protection, such constitutional policy does not require individuals to remain
trapped in a marriage where one spouse is genuinely psychologically incapable
of assuming the essential marital obligations contemplated by law. Accordingly,
the Supreme Court DENIED the Republic's Petition for Review on
Certiorari and AFFIRMED the Decision and Resolution of the Court of
Appeals declaring the marriage between Ma. Theresa Ramoran-Wong and Vincent L.
Wong VOID AB INITIO under Article 36 of the Family Code.