FACTS:

Petitioner Lester Benjamin S. Halili filed a petition to declare his marriage to respondent Chona M. Santos-Halili null and void based on his psychological incapacity. He claimed that they got married in a civil ceremony, thinking it was a joke, and they never lived together as husband and wife. They started fighting constantly a year later, and petitioner decided to stop seeing respondent and started dating other women until he received prank calls informing him that he was already married. Upon inquiry, he discovered that the marriage was not fake. The trial court found petitioner suffering from a mixed personality disorder, and declared the marriage null and void. However, the Court of Appeals (CA) reversed the decision, stating that the evidence failed to establish petitioner's psychological incapacity. The case was further elevated to the Supreme Court, which initially affirmed the CA's decision. Petitioner filed a motion for reconsideration, arguing that his marriage should be declared null and void based on his psychological incapacity. The Supreme Court ultimately granted the motion for reconsideration, stating that courts should interpret the provision on psychological incapacity on a case-to-case basis and consider expert opinions. The expert witness testified that petitioner suffered from a personality disorder brought about by a dysfunctional family and partner relational problems.

ISSUES:

1. Whether the evidence presented by petitioner is sufficient to establish his psychological incapacity.

2. Whether the CA erred in reversing the RTC's decision and declaring the marriage valid.

RULING:

1. Yes, the evidence presented by petitioner is sufficient to establish his psychological incapacity. The testimony of petitioner's expert witness, Dr. Natividad Dayan, revealed that petitioner was suffering from dependent personality disorder, which directly affected his capacity to comply with his essential marital obligations.

2. No, the CA did not err in reversing the RTC's decision. However, upon reconsideration, this Court found that the evidence presented by petitioner, including the expert opinion, supports the finding of his psychological incapacity. Thus, the marriage between petitioner and respondent is declared null and void.

PRINCIPLES:

• Courts should interpret the provision on psychological incapacity on a case-to-case basis, guided by experience, expert opinions, and decisions of church tribunals. (Te v. Yu-Te and the Republic of the Philippines)

• Expert opinion on the psychological and mental disposition of the parties is essential in determining psychological incapacity. (Te v. Yu-Te and the Republic of the Philippines)