Rosanna Tan-Andal vs Mario Andal

GR No. 196359; May 11, 2021.

DOCTRINE:

Psychological incapacity is neither a mental incapacity nor a personal disorder that must be proven through expert opinion.

FACTS:

Rosanna filed for a petition for declaration of nullity of marriage on the ground of Mario’s psychological incapacity to comply with his essential marital obligations to her.  Mario was diagnosed with narcissistic antisocial personality disorder and substance abuse disorder with psychotic features. 

The RTC voided the marriage. The CA reversed RTC’s ruling on the ground that the psychiatric evaluation of Mario is “unscientific and unreliable” since he was not interviewed. 

ISSUE: 

Whether or not the marriage is void due to psychological incapacity

HELD:

YES. The Court finds Mario psychologically incapacitated to comply with his essential marital obligations. Rosanna discharged the burden of proof required to nullify her marriage to Mario. Clear and convincing evidence  ( the Court held that the plaintiff-spouse must prove his or her case with clear and convincing evidence. This is a quantum of proof that requires more than preponderant evidence but less than proof beyond reasonable doubt) of Mario’s psychological incapacity consisted mainly of testimony on Mario’s personality structure and how it was formed primarily through his childhood and adult experiences, well before he married Rosanna.

That drug addiction is a ground for legal separation will not prevent this Court from voiding the marriage in this case. So long as a party can demonstrate that the drug abuse is a manifestation of psychological incapacity existing at the time of the marriage, this should be enough to render the marriage void under Article 36 of the Family Code.

Psychological incapacity is neither a mental incapacity nor a personal disorder that must be proven through expert opinion. There must be proof, however, of the durable or enduring aspects of a person’s personality, called “personality structure”, which manifests itself through clear acts of dysfunctionality that undermine the family. The spouse’s personality structure must make it impossible for him or her to understand and more important to comply with his or her marital obligations.  Proof of these aspects of personality need not be given by an expert. Ordinary witnesses who have been present in the life of the spouses before the latter contracted marriage may testify on behaviors that they have consistently observed from the supposedly incapacitated spouse. From there, the judge will decide if these behaviors are indicative of a true and serious incapacity to assume the essential marital obligations. The Code Committee’s intent to limit the incapacity to “psychic causes” is fulfilled. There will be no need to label a person as having a mental disorder just to obtain a decree of nullity. 

A party to a nullity case is still required to prove judicial antecedence because it is an explicit requirement of the law. Art. 35 is clear that the psychological incapacity must be existing at the time of the celebration of marriage, even if such incapacity becomes manifest only after solemnization.  Proof of juridically antecedent psychological incapacity may consist of testimonies describing the environment where the supposedly incapacitated spouse lived that may have led to a particular behavior. Furthermore, not being an illness in a medical sense, psychological incapacity is not something to be cured. And even if it were a mental disorder, it cannot be described in terms of being curable or incurable. 

Psychological incapacity contemplated in Article 36 means that the incapacity is so enduring and persistent with respect to a specific partner, and contemplates a situation where the couple’s respective personality structures are so incompatible and antagonistic that the only result of the union would be the inevitable and irreparable breakdown of the marriage. The psychological incapacity cannot be mere “refusal, neglect[,] or difficulty, much less ill will.” In other words, it must be shown that the incapacity is caused by a genuinely serious psychic cause.

To summarize, psychological incapacity consists of clear acts of dysfunctionality that show a lack of understanding and concomitant compliance with one’s essential marital obligations due to psychic causes. It is not a medical illness that has to be medically or clinically identified; hence, expert opinion is not required. As an explicit requirement of the law, the psychological incapacity must be shown to have been existing at the time of the celebration of the marriage, and is caused by a durable aspect of one’s personality structure, one that was formed before the parties married. Furthermore, it must be shown caused by a genuinely serious psychic cause. To prove psychological incapacity, a party must present clear and convincing evidence of its existence.

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