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REPUBLIC v. KATRINA S. TOBORA-TIONGLICO

FACTS:

The case involves a petition for declaration of nullity of marriage filed by Katrina Tabora-Tionglico against her husband Lawrence Tionglico. Katrina alleged that Lawrence was psychologically incapacitated to fulfill his marital obligations. She claimed that their marriage was marred by bickering and quarrels from the early stages and that Lawrence was distant and immature in his actions. He refused to help in rearing their child and would often taunt Katrina. They separated in 2003 due to incessant fighting. Katrina consulted with a psychiatrist, who diagnosed Lawrence with Narcissistic Personality Disorder. The Regional Trial Court (RTC) granted the petition and declared the marriage void ab initio. The Court of Appeals affirmed the RTC decision. Lawrence filed a petition for review on certiorari. The issue before the court is whether the totality of evidence presented by Katrina supports the findings of psychological incapacity.

ISSUES:

  1. Whether the petitioner sufficiently proved that the respondent is psychologically incapacitated to discharge the duties expected of a husband.

  2. Whether the findings of the clinical psychologist were based solely on biased information provided by the petitioner.

  3. Whether the evidence presented is sufficient to prove the psychological incapacity of the respondent-appellee.

  4. Whether the behavior exhibited by the husband rises to the level of psychological incapacity.

RULING:

  1. The petitioner failed to sufficiently prove that the respondent is psychologically incapacitated. The trial court must base its judgment on the totality of evidence adduced in the proceedings, not solely on expert opinions. The petitioner's expert opinions were based solely on the petitioner's statements, and the respondent did not participate in the proceedings or provide input. Therefore, the evidence was clearly wanting.

  2. The findings of the clinical psychologist were based solely on biased information provided by the petitioner. It is not credible to rely on a psychological evaluation that is one-sided and derived from information provided by a party with a bias for their cause.

  3. The Court ruled that the evidence presented is insufficient to prove the psychological incapacity of the respondent-appellee. The testimony of the appellant and the report of the clinical psychologist were considered self-serving and lacked serious evidentiary value. The court also held that the behavior exhibited by the husband, such as frequent fights, insensitivity, immaturity, and frequent night-outs, does not rise to the level of psychological incapacity required by law.

PRINCIPLES:

  • The burden of proof to show the nullity of a marriage belongs to the plaintiff, and any doubt should be resolved in favor of the existence and continuation of the marriage.

  • The root cause of 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 be proven to be existing at the time of the celebration of the marriage.

  • The incapacity must be shown to 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 defined in the Family Code.

  • Interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines should be 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, and no decision should be handed down unless the Solicitor General issues a certification stating their agreement or opposition to the petition.

  • Conclusions and generalizations on a spouse's psychological condition based on information fed by only one side is equivalent to admitting hearsay evidence.

  • The psychological illness that must afflict a party at the inception of the marriage should be a malady so grave and permanent as to deprive the party of awareness of the duties and responsibilities of the matrimonial bond.

  • Bare allegations, unsubstantiated by evidence, are not equivalent to proof.

  • Mere allegations are not evidence.