Jocelyn Suazo vs Angelito Suazo

G.R. No. 164493 – 629 Phil. 157 – 615 SCRA 154 – Civil Law – Persons and Family Relations – Family Code – Article 36; Psychological Incapacity – Drunkenness, Indolence, Physical Violence Not Necessarily Psychological Incapacity

In 1985, Jocelyn and Angelito Suazo met each other. They were just 16 years old at that time. In 1986, they got married before the Mayor of Biñan, Laguna. But their marriage did not turn out to be ideal. It was Jocelyn who had to work while Angelito was lazy. When confronted by Jocelyn, Angelito would beat her. Angelito was also constantly drunk. And in 1987, Angelito left Jocelyn for another woman.

In 1997, Jocelyn filed a petition to have their marriage be declared void on the ground that Angelito was psychologically incapacitated.

In court, Jocelyn presented Dr. Nedy Tayag who testified that based on her interview with Jocelyn and the description fed to her by Jocelyn, she concluded that Angelito is psychologically incapacitated to perform the essential marital obligations.

The RTC voided the marriage but the Court of Appeals reversed the decision.

ISSUE: Whether or not the marriage should be annulled on the ground of psychological incapacity.

HELD: No. The psychologist, using meager information coming from a directly interested party (Jocelyn), could not have secured a complete personality profile and could not have conclusively formed an objective opinion or diagnosis of Angelito’s psychological condition.

Further, habitual drunkenness, gambling and refusal to find a job, while indicative of psychological incapacity, do not, by themselves, show psychological incapacity. All these simply indicate difficulty, neglect or mere refusal to perform marital obligations that cannot be considered to be constitutive of psychological incapacity in the absence of proof that these are manifestations of an incapacity rooted in some debilitating psychological condition or illness.

Anent Angelito’s violent tendencies, physical violence on women indicates abnormal behavioral or personality patterns, however, such violence, standing alone, does not constitute psychological incapacity. Jurisprudence holds that there must be evidence showing a link, medical or the like, between the acts that manifest psychological incapacity and the psychological disorder itself. In this case, the psychologist failed to link the violence to psychological incapacity. Even assuming, therefore, that Jocelyn’s account of the physical beatings she received from Angelito were true, this evidence does not satisfy the requirement of Article 36 and its related jurisprudence, specifically the requisites provided for in the case of Santos vs CA.

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