FACTS:

Mary Christine C. Go-Yu filed a Petition for Declaration of Nullity of Marriage and Dissolution of the Absolute Community of Property against Romeo A. Yu in the Regional Trial Court (RTC). Go-Yu alleged that she grew up to become independent and confident and worked her way up to become the Senior Vice President of their family business. She claimed that after getting married to Yu, they stayed in his family home where she had to deal with constant meddling from her mother-in-law. She also mentioned that their sexual activity decreased and she was unable to conceive. Go-Yu further contended that she was diagnosed with Narcissistic Personality Disorder which existed before their marriage. She sought the dissolution of their absolute community of properties.

In his Amended Answer, Yu denied the allegations and stated that he wanted to reconcile and save their marriage. He also argued that the properties mentioned by Go-Yu were not part of the absolute community. The case proceeded to trial where Go-Yu presented documentary and testimonial evidence. After she rested her case, Yu filed a Demurrer to Evidence claiming that Go-Yu's alleged personality disorder was not supported by clear evidence. The RTC denied the Demurrer to Evidence, and Yu's Motion for Reconsideration was also denied.

Yu then filed a certiorari petition with the Court of Appeals (CA) assailing the orders of the RTC. The CA granted the Demurrer to Evidence and dismissed Go-Yu's petition for nullity of marriage.

The petitioner filed a Petition for Declaration of Nullity of Marriage and Dissolution of the Absolute Community of Property. The Court of Appeals (CA) ruled that the evidence presented by the petitioner failed to establish any proof of a disabling factor that incapacitated her from complying with her essential marital obligations.

The case involves a petition for certiorari filed by the petitioner, questioning the denial of her demurrer to evidence by the trial court. The petitioner argues that the trial court committed grave abuse of discretion in denying her demurrer to evidence, which questioned the sufficiency of the respondent's evidence to prove her petition for declaration of nullity of marriage based on psychological incapacity.

The petitioner filed a petition with the Regional Trial Court (RTC) seeking to declare her marriage to the respondent as null and void due to her psychological incapacity. The petitioner claimed that her marriage was void from the beginning.

ISSUES:

1. Whether the trial court committed grave abuse of discretion in denying the respondent's motion to dismiss on demurrer to evidence.

2. Whether the petitioner was able to produce sufficient evidence to make out her case or sustain a verdict.

3. Whether the totality of evidence presented is enough to sustain a finding of psychological incapacity even without actual medical or psychological examination.

4. Whether the psychological report presented in this case is sufficient to establish the existence of psychological incapacity.

5. Whether or not the petitioner is aware of and has performed the essential obligations of a married individual.

6. Whether or not the petitioner's actions demonstrate her understanding of the purposes and responsibilities of marriage.

7. Whether the petitioner's feelings of disappointment or disillusionment towards her husband and marriage is a sufficient ground to have the marriage declared null and void.

8. Whether the respondent's admission in his original answer can be used as a basis for the court's judgment.

9. Whether the burden of proof to show the nullity of marriage lies with the plaintiff.

10. Whether the evidence presented clearly reveals a situation where the parties, or one of them, could not have validly entered into a marriage by reason of a grave and serious psychological illness existing at the time it was celebrated.

RULING:

1. The Court held that the trial court committed grave abuse of discretion in denying the respondent's motion to dismiss on demurrer to evidence. The petitioner was unable to present sufficient evidence to show that she has the right to the relief she seeks.

2. Yes, the totality of evidence presented is enough to sustain a finding of psychological incapacity even without actual medical or psychological examination. The trial court must base its decision not solely on the expert opinions furnished by the parties but also on the totality of evidence adduced in the course of the proceedings.

3. No, the psychological report presented in this case is not sufficient to establish the existence of psychological incapacity. The report lacks material facts, acceptable discussion and analysis, to support the supposed expert opinion of the psychiatrist. The methodology employed in the report does not satisfy the required depth and comprehensiveness of examination. The report also heavily relies on the accounts provided by the petitioner herself, which is deemed inherently self-serving and should be held to the strictest standard of scrutiny. Additionally, there is no other competent and credible proof that the alleged disorder is grave enough to bring about the disability and that said disorder is permanent or clinically incurable.

4. The petitioner's documentary and testimonial evidence indicate that she is fully aware of and has performed the essential obligations of a married individual. This is evidenced by her concern over the decrease in sexual activity, her desire to have a baby, her adjustments and sacrifices in their financial situation, and her help in managing their household.

5. The petitioner's actions show her understanding of the purposes and responsibilities of marriage. She acknowledged the importance of a healthy sexual relationship and believed that having a baby is part of the purpose of marriage. She also recognized that adjustments and sacrifices are necessary in marriage.

6. No, the petitioner's feelings of disappointment or disillusionment towards her husband and marriage are not sufficient grounds to have the marriage declared null and void. The Court held that an unsatisfactory marriage is not a null and void marriage. Article 36 of the Family Code, which pertains to psychological incapacity, refers to a serious psychological illness afflicting a party even before the celebration of the marriage. Mere irreconcilable differences and conflicting personalities do not constitute psychological incapacity.

7. No, the respondent's admission in his original answer cannot be used as a basis for the court's judgment. The Court ruled that the original answer has been amended, and settled is the rule that amended pleadings supersede or amend the original pleadings. Additionally, under Article 48 of the Family Code, no judgment in cases of annulment or declaration of absolute nullity of marriage shall be based on a stipulation of facts or confession of judgment.

8. Yes, the burden of proof to show the nullity of marriage lies with the plaintiff.

9. No, the evidence presented does not clearly reveal a situation where the parties, or one of them, could not have validly entered into a marriage by reason of a grave and serious psychological illness existing at the time it was celebrated.

PRINCIPLES:

• Psychological incapacity, as construed under the law, must be grave and serious, rooted in the history of the party before the marriage, and incurable.

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

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

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

• The incapacity 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 Articles 68 to 71 of the Family Code.

• Interpretations of the National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines should be given great respect.

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

• Expert opinions are highly advisable but not indispensable evidence in determining the merits of a case. The totality of evidence presented is enough to sustain a finding of psychological incapacity.

• The totality of evidence presented must be considered in determining the existence of psychological incapacity in a nullity of marriage case, and actual medical or psychological examination is not always necessary.

• Expert opinions in nullity of marriage cases must be supported by material facts, acceptable discussion and analysis.

• The methodology employed in assessing psychological incapacity must satisfy the required depth and comprehensiveness of examination.

• The party claiming psychological incapacity must provide competent and credible proof of the existence of the alleged disorder, showing that it is grave enough to bring about the disability and that it is permanent or clinically incurable.

• Marriage entails essential obligations that need to be performed by both parties.

• A healthy sexual relationship is an important aspect of marriage.

• Procreation is one of the purposes of marriage.

• Adjustments and sacrifices are necessary in a marriage.

• Both spouses have responsibilities and roles to fulfill in a marriage.

• A marriage cannot be declared null and void based solely on feelings of disappointment or disillusionment towards the spouse or marriage. There must be a serious psychological illness afflicting a party before the celebration of the marriage.

• Mere irreconcilable differences and conflicting personalities do not amount to psychological incapacity as defined under Article 36 of the Family Code.

• Amended pleadings supersede or amend the original pleadings and cease to be judicial admissions.

• In cases of annulment or declaration of absolute nullity of marriage, no judgment shall be based on a stipulation of facts or confession of judgment.

• The burden of proof to show the nullity of marriage lies with the plaintiff.

• Unless the evidence presented clearly reveals a situation where the parties, or one of them, could not have validly entered into a marriage by reason of a grave and serious psychological illness existing at the time it was celebrated, the court is compelled to uphold the indissolubility of the marital tie.