Nicolas Matudan and Marilyn Matudan married in 1976. After four children and ten years of marriage (1986), Marilyn sought permission from Nicolas for her to work abroad. Nicolas gave his permission to Marilyn but after she went abroad, Marilyn was never seen or heard of again.
In June 2008, Nicolas filed a petition for declaration of nullity of marriage on the ground that he and Marilyn were psychologically incapacitated. To prove this, he submitted the findings of Dr. Nedy Tayag who found Nicolas to be suffering from Passive-Aggressive Personality Disorder and Marilyn was suffering from Narcissistic Personality Disorder with Antisocial Traits.
Dr. Tayag based her findings from her interviews with Nicolas and Maricel, one of the children of Nicolas and Marilyn.
Dr. Tayag’s conclusion on the psychological incapacity of Nicolas can be attributed to his being an abandoned child. At a young age, his parents separated and he was left in the custody of his paternal grandmother. He lacked a support system and felt rejected. He developed a strong need for nurturance, love and attention and that he would do anything to attain such. Meanwhile, Dr. Tayag’s findings on the psychological incapacity of Marilyn were her preoccupation with pursuing matters that would make her happy; has a high sense of self-importance; wants to have her way and disregards her husband’s opinions; lacks empathy; wants to have a good life. Her personality condition is rooted on her unhealthy familial environment. She came from an impoverished family. Her parents were more pre-occupied with finding ways to make ends meet to such extent that they failed to give adequate attention and emotional support to their children.
Dr. Tayag further testified that the psychological condition of Nicolas and Marilyn are grave and characterized by juridical antecedence as the same already existed before they got married, their disorders having been in existence since their childhood years are permanent and severe.
The trial proceeded without the participation of Marilyn. After the presentation of Nicolas’ evidence, the trial court dismissed his petition. The Court of Appeals affirmed the decision of the trial court.
The ground for the dismissal of the petition was that Nicolas failed to prove his psychological incapacity as well as that of Marilyn.
ISSUE: Whether or not a finding of psychological incapacity by a psychologist may be based solely on the information from the person seeking annulment.
HELD: YES but the Supreme Court ruled that in cases where the only basis of a psychologist’s findings is that coming from the petitioner (person seeking the marriage to be annulled), the psychologist’s findings deserve the application of a more rigid and stringent set of standards. In this case, although the psychological incapacity of Nicolas was established, it was not proven that such was characterized by gravity, juridical antecedence, and incurability. This is compounded by the fact that Nicolas contradicted his own claims by testifying that he and Marilyn were happily married and never had a fight, which is why they begot four children; and the only reason for his filing the annulment was Marilyn’s complete abandonment of the marriage and family when she left to work abroad.
On the other hand, Marilyn’s psychological incapacity was not sufficiently proven. Dr. Tayag’s supposed expert findings regarding Marilyn’s psychological condition were not based on actual tests or interviews conducted upon Marilyn herself; they are based on the personal accounts of Nicolas. This fact gave more significance and importance to Nicolas’ other pieces of evidence, which could have compensated for the deficiency in the expert opinion which resulted from its being based solely on Nicolas’ one-sided account.
But the testimony of Nicolas was also insufficient. Based on the record, Nicolas failed to state in detail the alleged acts which comprised Marilyn’s irresponsibility, immaturity, or selfishness.
The Supreme Court also gave little weight to Maricel’s testimony as she was merely two years old when Marilyn left. Growing up, she may have seen the effects of Marilyn’s abandonment – such as the lack of emotional and financial support; but she could not have any idea of her mother’s claimed psychological incapacity, as well as the nature, history, and gravity thereof.
A psychologist’s finding must be discussed in-depth and comprehensively to warrant a conclusion that a psychological incapacity existed that prevented a married person from complying with the essential obligations of marriage.
