Facts:
Noel
and Maribel were schoolmates at the Mapua Institute of Technology where both
took up Electronics and Communications Engineering. Sometime in 1990, they were
introduced by a mutual friend and became close to one another. Noel courted
Maribel, but it was only after years of continuous pursuit that Maribel
accepted Noels proposal and the two became sweethearts. Noel considered Maribel
as the snobbish and hard-to-get type, which traits he found attractive. Noel’s
family was aware of their relationship for he used to bring Maribel to their
house. Noel observed that Maribel was inordinately shy when around his family
so to bring her closer to them, he always invited Maribel to attend family
gatherings and other festive occasions like birthdays, Christmas, and fiesta
celebrations. Maribel, however, would try to avoid Noels invitations and
whenever she attended those occasions with Noels family, he observed that
Maribel was invariably aloof or snobbish. Not once did she try to get close to
any of his family members. Noel would talk to Maribel about her attitude
towards his family and she would promise to change, but she never did.
Around
1997, Noel decided to break up with Maribel because he was already involved
with another woman. He tried to break up with Maribel, but Maribel refused
and offered to accept Noels relationship with the other woman so long as they
would not sever their ties. To give Maribel some time to get over their
relationship, they still continued to see each other albeit on a friendly
basis.
Despite
their efforts to keep their meetings strictly friendly, however, Noel and
Maribel had several romantic moments together. Noel took these episodes of
sexual contact casually since Maribel never demanded anything from him except
his company. Then, sometime in November 1998, Maribel informed Noel that she
was pregnant with his child. Upon advice of his mother, Noel grudgingly agreed
to marry Maribel. Noel and Maribel were immediately wed on November 23, 1998 before Judge Gregorio Dayrit, the Presiding Judge of
the Metropolitan Trial Court of Quezon City.
After the marriage ceremony, Noel and
Maribel agreed to live with Noels family in their house at Rosal,
Pag-asa, Quezon City. During all the time she lived with Noels family,
Maribel remained aloof and did not go out of her way to endear herself to them.
She would just come and go from the house as she pleased. Maribel never
contributed to the familys coffer leaving Noel to shoulder all expenses for
their support. Also, she refused to have any sexual contact with Noel. Surprisingly, despite Maribels claim of being
pregnant, Noel never observed any symptoms of pregnancy in her. He asked
Maribels office mates whether she manifested any signs of pregnancy and they
confirmed that she showed no such signs. Then, sometime in January 1999,
Maribel did not go home for a day, and when she came home she announced to Noel
and his family that she had a miscarriage and was confined at the Chinese
General Hospital where her sister worked as a nurse.
Noel confronted her about her alleged
miscarriage sometime in February 1999. The discussion escalated into an intense
quarrel which woke up the whole household. Noels mother tried to intervene but
Maribel shouted Putang ina nyo,
wag kayo makialam at her.
On September 11, 2000 or after less than two years of marriage, Noel filed
a petition for declaration of nullity of marriage with the RTC of
Manila.
RTC: Found that Maribel
failed to perform the essential marital obligations of marriage, and such
failure was due to a personality disorder called Narcissistic Personality
Disorder characterized by juridical antecedence, gravity and incurability as
determined by a clinical psychologist. The RTC cited the findings of Nedy L.
Tayag, a clinical psychologist presented as witness by Noel, that Maribel was a
very insecure person. She entered into the marriage not because of
emotional desire for marriage but to prove something, and her attitude was
exploitative particularly in terms of financial rewards. She was emotionally
immature, and viewed marriage as a piece of paper and that she can easily get
rid of her husband without any provocation.
CA reversed the decision of the RTC.
Issue: W/ON the marriage between
the parties is null and void under Article 36 of the Family Code?
Held: No. The Court
held in Santos v. Court of Appeals. that the phrase psychological incapacity is
not meant to comprehend all possible cases of psychoses. It refers to no less
than a mental (not physical) incapacity that causes a party to be truly
noncognitive of the basic marital covenants that concomitantly must be assumed
and discharged by the parties to the marriage which, as expressed by Article 68 of the Family Code, include their mutual obligations to live
together, observe love, respect and fidelity and render help and support.
The intendment of the law has been to confine it to the most serious of
cases of personality disorders clearly demonstrative of an utter insensitivity
or inability to give meaning and significance to the marriage.
The totality of evidence presented by Noel was not
sufficient to sustain a finding that Maribel was psychologically incapacitated.
Noels evidence merely established that Maribel refused to have sexual
intercourse with him after their marriage, and that she left him after their
quarrel when he confronted her about her alleged miscarriage. He failed to
prove the root cause of the alleged psychological incapacity and establish the
requirements of gravity, juridical antecedence, and incurability. As
correctly observed by the CA, the report of the psychologist, who concluded
that Maribel was suffering from Narcissistic Personality Disorder traceable to
her experiences during childhood, did not establish how the personality
disorder incapacitated Maribel from validly assuming the essential obligations
of the marriage. Indeed, the same psychologist even testified that Maribel
was capable of entering into a marriage except that it would be difficult for
her to sustain one. Mere difficulty, it must be stressed, is not the incapacity
contemplated by law.
