G.R. No. 170925 – 619 Phil. 434 – 604 SCRA 444 – Civil Law – Persons and Family Relations – Family Code – Marriage – Void Marriages – Article 36; Psychological Incapacity – Gravity, Juridical Antecedence, Incurability
In 1977, Rodolfo Aspillaga and Aurora Apon met each other in college. They became sweethearts after 5 months of courtship. In 1982, they got married. In 1983, they again married each other as a sign of affirmation of their love to each other.
But in 1991, when Aurora returned from Japan, she discovered that Rodolfo was living with her cousin. From that point, their marital relations soured. In 1992, Rodolfo left Aurora to live with her cousin.
In 1995, Aurora filed a petition for annulment of marriage on the ground that Rodolfo is psychologically incapacitated.
Dr. Eduardo Maaba evaluated Rodolfo and Aurora. After evaluation, he concluded that both are psychologically incapacitated. He explained that due to Aurora’s dark and traumatic childhood past, she has the tendency for self dramatization and attention-getting behavior. Lapses in judgment and shallow heterosexual relationship was projected. Sign of immaturity and desire to regress to a lower level of development were likewise projected. Self-esteem was also low. Deep-seated sense of dejection, loneliness and emptiness hamper her objectivity.
On the part of Rodolfo, the doctor found that: he is an intelligent adult male, who is egoistic and harbors an inner sense of inadequacy, helplessness and anxiety in losing agility. He, however, projects himself as dominant person, to cover his deep-seated insecurity and inadequacy. He tends to be suspicious and blames others for his mistakes. He claims for adulation, reassurance and attention from other people. These can be traced from an unhealthy familial relationship during the early maturational development specifically in the form of a domineering and protective maternal image.
ISSUE: Whether or not both are psychologically incapacitated.
HELD: No. Dr. Maaba only found that Rodolfo and Aurora are suffering from psychological disorders but not the kind contemplated under the law on psychological incapacity which renders them incapable to perform essential marital obligations.
Psychological incapacity required by Art. 36 must be characterized by (a) gravity, (b) juridical antecedence, and (c) incurability. In this case, the foregoing were not met. Dr. Maaba failed to reveal that these personality traits or psychological conditions were grave or serious enough to bring about an incapacity to assume the essential obligations of marriage.
Mere difficulty is not synonymous to incapacity. Moreover, there is no evidence to prove that each party’s condition is so grave or is of such nature as to render said party incapable of carrying out the ordinary duties required in marriage. There is likewise no evidence that the claimed incapacity is incurable and permanent. Note also that they actually had a good marriage at first and their quarrel only began when Rodolfo cheated on her with her cousin, hence, the allege psychological incapacity was not proven to have existed at the time of their marriage.
