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JOCELYN M. SUAZO v. ANGELITO SUAZO

FACTS:

Jocelyn Suazo filed a petition for the nullity of her marriage to Angelito Suazo, claiming that Angelito is psychologically incapacitated. Jocelyn testified that Angelito suffered from Anti-Social Personality Disorder, which affects his ability to have a harmonious relationship. She also stated incidents of physical abuse and lack of respect from Angelito. The court found that Angelito's psychological incapacity had caused significant hardship to Jocelyn and granted the petition.

The Republic appealed the decision to the Court of Appeals, which reversed the trial court's ruling. The CA stated that the evidence presented was insufficient to prove Angelito's psychological incapacity. The aggregate testimony from Jocelyn, her family, and a social worker was deemed inconclusive. The CA also questioned the psychologist's theory, emphasizing the need for an evaluation of Angelito himself.

Jocelyn argues that the RTC's decision should be upheld and cites case law to support her position. She contends that Article 36 of the Family Code does not provide a specific definition of psychological incapacity, giving the courts discretion in interpreting the term. The OSG opposes the nullification, emphasizing the lack of specificity in the RTC's finding.

The issue is whether there is a legal basis to nullify Jocelyn and Angelito's marriage under Article 36 of the Family Code.

ISSUES:

  1. Whether expert opinion is necessary in a petition for declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code.

  2. Whether the guidelines set in the case of Molina v. People's Bank and Trust Company still apply in determining psychological incapacity.

  3. Whether the relaxation of the requirements set forth in Molina v. Reyes for the declaration of nullity of marriages based on psychological incapacity is applicable in this case.

  4. Whether Jocelyn presented sufficient evidence to establish Angelito's psychological incapacity to perform essential marital obligations.

  5. Whether the psychologist's report and testimony provided sufficient evidence of Angelito's psychological incapacity.

  6. Whether Jocelyn's testimony provided sufficient evidence of Angelito's psychological incapacity.

  7. Whether physical violence alone constitutes psychological incapacity under Article 36 of the Family Code.

  8. Whether there is sufficient evidence showing a link between the acts that manifest psychological incapacity and the psychological disorder itself.

RULING:

  1. Expert opinion is no longer necessary in a petition for declaration of nullity of marriage based on psychological incapacity. The totality of evidence showing the existence of psychological incapacity and its gravity, juridical antecedence, and incurability can be sufficient to establish the ground for nullity of marriage under Article 36 of the Family Code. (Marcos v. Marcos)

  2. The guidelines set in the case of Molina v. People's Bank and Trust Company still apply in determining psychological incapacity in cases then already pending. The interpretation and construction of the law by the court establishes the contemporaneous legislative intent, making it part of the law from the date the statute is enacted. (Pesca v. Pesca)

  3. The relaxation of the requirements set forth in Molina v. Reyes for the declaration of nullity of marriages based on psychological incapacity is not applicable in this case. The Court found that Jocelyn's evidence was insufficient to establish Angelito's psychological incapacity.

  4. The psychologist's report and testimony were deemed insufficient to establish Angelito's psychological incapacity. The psychologist heavily relied on information from Jocelyn, a party with a bias and interest in the case. The court found that the psychologist's report did not meet the required standards for a conclusive diagnosis of psychological incapacity. The psychologist failed to conduct a thorough assessment of Angelito and did not provide a complete personality profile. The report and testimony also lacked specific bases for the conclusions made about Angelito's disorder.

  5. Jocelyn's testimony also did not provide sufficient evidence of Angelito's psychological incapacity. She testified about Angelito's habitual drunkenness, gambling, refusal to seek employment, and physical beatings, but most of these incidents occurred after the marriage. The court emphasized that the psychological incapacity must exist at the time of the celebration of the marriage. The acts of habitual drunkenness, gambling, and refusal to find a job, while indicative of psychological incapacity, do not prove that these behaviors are rooted in a debilitating psychological condition. Only the physical violence allegedly inflicted on Jocelyn may indicate an abnormal behavioral or personality pattern, but the lack of clarification as to when these beatings occurred created an evidentiary gap.

  6. Physical violence alone does not constitute psychological incapacity. It must be shown that there is a link between the acts that manifest psychological incapacity and the psychological disorder itself.

  7. In this case, there is no evidence showing a link between the acts of physical violence and a psychological disorder. The opinion of the psychologist cannot be relied upon, rendering it insufficient to establish psychological incapacity.

PRINCIPLES:

  • The burden of proof to show the nullity of the marriage belongs to the plaintiff. Any doubt should be resolved in favor of the existence and continuation of the marriage and against its dissolution and nullity. This is rooted in the fact that both the Constitution and laws of the Philippines cherish the validity of marriage and unity of the family.

  • The root cause of the psychological incapacity must be (a) medically or clinically identified, (b) alleged in the complaint, (c) sufficiently proven by experts, and (d) clearly explained in the decision. The incapacity must be psychological, not physical, although its manifestations and symptoms may be physical. Expert evidence may be given by qualified psychiatrists and clinical psychologists.

  • The incapacity must be proven to be existing at the time of the celebration of the marriage. The illness need not be perceivable at that time, but it must have attached at that moment or prior thereto.

  • The incapacity must be shown to be medically or clinically permanent or incurable. It must be relevant to the assumption of marriage obligations. The illness must be grave enough to bring about the disability of the party to assume the essential obligations of marriage.

  • The essential marital obligations must be those embraced by Articles 68 up to 71 of the Family Code as regards the husband and wife, as well as Articles 220, 221, and 225 of the same Code in regard to parents and their children.

  • Interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines, while not controlling or decisive, should be given great respect by the courts.

  • The trial court must order the prosecuting attorney or fiscal and the Solicitor General to appear as counsel for the state. No decision shall be handed down unless the Solicitor General issues a certification, briefly stating the reasons for agreement or opposition to the petition.

  • Expert opinion is not necessary in proving psychological incapacity under Article 36 of the Family Code.

  • The Molina guidelines still apply in determining psychological incapacity in cases then already pending.

  • Courts should interpret the provision on a case-to-case basis, guided by experience, the findings of experts and researchers in psychological disciplines, and by decisions of church tribunals.

  • The relaxation of the requirements for the declaration of nullity of marriages based on psychological incapacity was deemed necessary due to the high cost and limited availability of experts. The need for the examination of a party by an expert and the presentation of expert testimony shall now be determined by the court during the pre-trial conference.

  • Expert testimony is crucial in establishing the precise cause of a party's psychological incapacity and showing that it existed at the inception of the marriage.

  • The evidence must show a link between the acts that manifest psychological incapacity and the psychological disorder itself.

  • The intention of the law is to confine the application of Article 36 to the most serious cases of personality disorders that render a party unable to give meaning and significance to the marriage.

  • Mere difficulty, refusal, or neglect in performing marital obligations, as well as irreconcilable differences, sexual infidelity or perversion, emotional immaturity and irresponsibility, do not warrant a finding of psychological incapacity.

  • A psychologist's report and testimony must be based on a thorough and in-depth examination of the parties involved to establish a conclusive diagnosis of psychological incapacity.

  • Information from persons intimately related to a party may be considered in the absence of a personal examination, but the credibility and reliability of such information must be carefully evaluated.

  • Psychological incapacity must exist at the time of the celebration of the marriage.

  • Acts of habitual drunkenness, gambling, and refusal to perform marital obligations alone do not prove psychological incapacity unless they can be shown to be manifestations of a debilitating psychological condition.

  • Physical violence alone does not constitute psychological incapacity. There must be evidence of a link between the acts that manifest psychological incapacity and the psychological disorder itself.

  • The opinion of a psychologist must be relied upon to establish the link between the acts and the psychological disorder.