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GERARDO A. ELISCUPIDEZ v. GLENDA C. ELISCUPIDEZ

FACTS:

Petitioner Gerardo A. Eliscupidez filed a Petition for Declaration of Nullity of Marriage against respondent Glenda C. Eliscupidez under Article 36 of the Family Code. Petitioner testified during the trial that they had frequent fights and respondent would throw things at him. Respondent allegedly tried to avoid getting pregnant and had a miscarriage with their supposed first child. She also forbade petitioner from interacting with other females, meeting friends and relatives, and wearing nice clothes. She even hit him with a knife on one occasion and insulted him due to his meager income. Despite giving her all his salary, respondent still incurred debts. Respondent neglected her responsibilities to their children and had an affair with another man, with whom she lived and had children. Petitioner presented witnesses who confirmed his testimony and a Psychological Evaluation Report stating that respondent had psychological incapacity. The Regional Trial Court declared the marriage void, but the Court of Appeals reversed the decision.

The petitioner alleged that the respondent had a flawed personality characterized by various negative traits and behaviors. The respondent neglected her family and prioritized her friends and the opposite sex, leading to a breakdown in their marriage. She engaged in extra-marital affairs and abandoned her family to live with her paramour. The petitioner argued that the respondent's psychological incapacity existed prior to their marriage and was deeply embedded within her personality. The Regional Trial Court (RTC) ruled in favor of the petitioner, declaring the marriage void ab initio. The Office of the Solicitor General (OSG) filed a motion for reconsideration, but it was denied by the RTC. The OSG appealed to the Court of Appeals, arguing that the RTC erred in declaring the marriage null and void based on the respondent's psychological incapacity.

ISSUES:

  1. Whether or not the respondent is psychologically incapacitated to perform her essential marital obligations

  2. Whether or not the CA committed an error of law in reversing the Decision of the RTC which granted the Petition for Declaration of Nullity of Marriage under Article 36 of the Family Code filed by the petitioner

  3. Whether the petitioner spouse has proven the psychological incapacity of the respondent spouse.

  4. Whether the report of Dr. Tayag should be given weight and credibility.

  5. Whether respondent exhibited psychological incapacity to assume marital responsibilities.

  6. Whether the marriage between petitioner and respondent can be declared null and void under Article 36 of the Family Code.

RULING:

  1. The Court denied the petition. It held that the burden of proving the nullity of marriage rests upon the petitioner, and any doubts regarding the validity of marriage should be resolved in favor of its continuance and validity. The Court emphasized that psychological incapacity as a ground for nullifying a marriage under Article 36 of the Family Code should refer to the most serious cases of personality disorders that demonstrate an insensitivity or inability to give meaning and significance to the marriage.

  2. The totality of the evidence presented by the petitioner failed to prove the psychological incapacity of the respondent spouse. The root cause of the alleged incapacity was not sufficiently proven by experts and was not shown to be permanent or incurable. Therefore, the nullity of the marriage cannot be declared.

  3. The report of Dr. Tayag should not be given credence as it was based on self-serving testimonial descriptions provided by the petitioner and his witnesses. The report failed to sufficiently explain the grave, deeply-rooted, and incurable nature of the respondent's alleged psychological incapacity, and it did not meet the required depth and comprehensiveness of examination. Independent evidence is necessary to prove the existence of psychological incapacity.

  4. The Court ruled that the marriage between petitioner and respondent cannot be declared null and void under Article 36 of the Family Code. The evidence on record did not establish that respondent was psychologically incapacitated to assume her marital responsibilities.

PRINCIPLES:

  • The burden of proving the nullity of marriage rests upon the petitioner.

  • Any doubts regarding the validity of marriage should be resolved in favor of its continuance and validity.

  • Psychological incapacity as a ground for nullifying a marriage should refer to the most serious cases of personality disorders that demonstrate an insensitivity or inability to give meaning and significance to the marriage.

  • Psychological incapacity, to be a ground for the nullity of marriage, must be characterized by gravity, juridical antecedence, and incurability.

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

  • Expert evidence from qualified psychiatrists and clinical psychologists may be given to establish psychological incapacity.

  • Psychological evaluations derived solely from one-sided sources, particularly from the spouse seeking nullity, may not be given weight and credibility.

  • The totality of the evidence presented must sufficiently prove that the psychological incapacity existed prior to the marriage and was grave, incurable, and permanent. Actual medical examination is not necessary if the totality of the evidence is enough to establish the party's psychological condition.

  • Psychological incapacity as a ground for the declaration of nullity of marriage must be proven by the party alleging it.

  • Mere evidence of "dramatic, extroverted behavior" or aggressive outbursts does not necessarily prove psychological incapacity.

  • The evidence should show that the incapacity is grave, incurable, and existing at the time of the celebration of the marriage.