FACTS:

Marivi and Nilo got married in 1986 and had two sons. Marivi filed a petition for declaration of nullity of marriage in 2005, citing Nilo's inadequate personality disorder and her own personality disorder of the mixed type. Marivi claimed that Nilo was unfaithful, non-committal to the marriage, made decisions without consulting her, withheld sexual contact, and preferred the company of his friends. Despite a reconciliation, Marivi claimed that Nilo never changed.

Marivi and Nilo Cruz were married in 1991 and had two sons. Marivi filed a petition for annulment of marriage on the ground of psychological incapacity. She alleged that Nilo neglected and failed to provide emotional, psychological, and physical support to her. She felt like they were merely housemates and that Nilo preferred to go out with his friends. Their conversations were superficial and he showed no interest in her or their children. Marivi also claimed that Nilo had no sense of companionship with their children and even told their son that their brand new house was everything to him. She further mentioned that Nilo had effeminate ways, was vain, and would have weekly "beauty" treatments. They stopped having sex after the birth of their second son because Nilo failed to have an erection. Marivi's father and younger sister also testified on her behalf, stating that the marriage was not harmonious and that Nilo was controlling and short-tempered.

The case involves a marriage between Nilo and Marivi who both filed a petition for the declaration of nullity of their marriage on the ground of psychological incapacity. The court appointed two expert witnesses, Dr. Villegas and Dr. Encarnacion, to conduct psychological evaluations of the parties.

According to Dr. Villegas, both Nilo and Marivi exhibited grave psychological disorders that affected their ability to function normally in their marriage. Nilo had issues with his masculinity and sought his mother's nurturing qualities from his wife. He displayed aggression in the form of passivity, refusing to engage in sexual activity with his wife. Nilo also exhibited compensatory behavior to cover up his weak masculine traits. On the other hand, Marivi had expectations of marriage based on her idealized interactions with her close-knit family. She had mood fluctuations, emotional immaturity, and low self-esteem. She had difficulty neutralizing negativity in her behavior and was suggestible, egocentric, and driven by a desire to "extort" from others. Dr. Villegas concluded that the couple's respective personality disorders were mutually repelling, and their brain waves were not in sync.

Marivi and Nilo were married but eventually encountered irreconcilable differences. Marivi sought the declaration of nullity of their marriage, alleging that Nilo exhibited psychological incapacity. Marivi claimed that Nilo prioritized his work over his family's emotional needs and lacked sexual interest in her. The Regional Trial Court (RTC) dismissed Marivi's petition, ruling that there was no sufficient evidence to support the claim of psychological incapacity. The court found that Marivi's need for assurance of love, derived from looking up to her father as her standard of an ideal husband, was not enough to declare her psychologically incapacitated. Likewise, the court found no concrete evidence of Nilo's oedipal complex and held that his prioritization of work was still beneficial to the family. The court also reasoned that Nilo's lack of sexual interest was a result of Marivi's behavior and not a psychological incapacity.

ISSUES:

1. Whether the marriage is void based on Article 36 of the Family Code.

2. Whether the psychological incapacity of the parties is proven.

3. Whether or not the failure to perform sexually and provide quality time for the family constitute psychological incapacity.

4. Whether or not the evidence presented supports the existence of psychological incapacity.

5. Whether there is no more functional marital life between the parties.

6. Whether the petitioner and respondent have a lack of trust and respect for each other.

7. Whether or not Nilo's womanizing activities and Marivi's feeling of being unvalued and unloved constitute psychological incapacity.

8. Whether or not Marivi's psychological incapacity is curable.

RULING:

1. The marriage is not void based on Article 36 of the Family Code. The court cites the guidelines in interpreting and applying Article 36, which include the requirement that the psychological incapacity must be characterized by gravity, juridical antecedence, and incurability. Mere irreconcilable differences or conflicting personalities do not constitute psychological incapacity.

2. The psychological incapacity of the parties is not proven. The court emphasizes that the incapacity must refer to the essential obligations of marriage and be tantamount to a psychological abnormality. In this case, the evidence does not show that the parties are incapable of fulfilling their marital duties due to some psychological illness.

3. The Supreme Court held that the failure to perform sexually and provide quality time for the family cannot be considered as psychological incapacity. The evidence presented showed that these issues were caused by factors other than a psychological disorder, such as work and marital stress, as well as ordinary human failings.

4. The evidence presented did not support the existence of psychological incapacity. The Court found that the failure to perform sexually was a case of "selective impotency" caused by the husband being turned off by the wife's disclosure of their bed secrets to her family. Additionally, the husband testified that the sexual problem only occurred after the birth of their second child and that he was unfairly blamed for it. The lack of quality time for the family was attributed to the husband's demanding job, which required him to entertain clients and principals from headquarters. The Court found that these factors did not demonstrate psychological incapacity as contemplated by law and jurisprudence.

5. The petitioner and respondent have different opinions on the existence of a functional marital life. The respondent believes that there is still a functional marital life, while the petitioner disagrees. The court did not make a definitive ruling on this issue based on the given information.

6. According to the psychiatrist's examination, the respondent sees the petitioner as negativistic and demanding, leading to a lack of trust between them.

7. The Supreme Court held that Nilo's womanizing activities and Marivi's feeling of being unvalued and unloved do not constitute psychological incapacity. Marivi failed to substantiate Nilo's womanizing activities as a manifestation of psychological incapacity and did not present irrefutable proof to corroborate her claims. On the other hand, Marivi's psychological incapacity, as assessed by a psychologist, was found to be curable. The psychologist stated that Marivi's needs were badly unfulfilled in the marriage but could be addressed if she were in a relationship with someone who can meet her needs. Thus, the Court concluded that the protagonists in the case are simply unwilling to work out their personality differences and are overwhelmed by disappointment and disillusionment towards each other, but this does not render the marriage null and void.

PRINCIPLES:

• Psychological incapacity under Article 36 of the Family Code must be characterized by gravity, juridical antecedence, and incurability.

• The burden of proof to show the nullity of the marriage rests on the plaintiff.

• The root cause of the psychological incapacity must be medically or clinically identified, alleged in the complaint, sufficiently proven by experts, and clearly explained in the decision.

• The incapacity must exist at the time of the celebration of the marriage and must be medically or clinically permanent or incurable.

• 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 are those embraced by the provisions of the Family Code regarding husband and wife, as well as parents and their children.

• Interpretations by the National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines are given great respect by courts.

• The trial court must order the prosecuting attorney or fiscal and the Solicitor General to appear as counsel for the state.

• Clinical findings of psychology experts are considered as part of the evidence, but the court is free to make its own independent factual findings.

• The failure to perform sexually and provide quality time for the family does not necessarily constitute psychological incapacity.

• The evidence presented must support the existence of psychological incapacity in order for a marriage to be annulled on such grounds.

• Lack of trust and respect can contribute to the breakdown of a marital relationship.

• Different perceptions and communication styles between spouses can lead to misunderstandings and conflicts in a marriage.

• To prove psychological incapacity, there must be a showing of clear and convincing evidence.

• Bare allegations and unsupported claims are not sufficient to establish psychological incapacity.

• Psychological incapacity may be deemed curable if the needs of the spouse can be addressed in a different relationship.