View full case

REPUBLIC v. ARIEL S. CALINGO

FACTS:

Ariel S. Calingo (Ariel) and Cynthia Marcellana-Calingo (Cynthia) met in 1978 when Cynthia was still the girlfriend of Ariel's friend. After Cynthia broke up with her then-boyfriend, she and Ariel became a couple. On February 5, 1980, Ariel and Cynthia got married civilly and initially lived in Paco, Manila. However, they later relocated multiple times due to Cynthia's alleged aggressive behavior. Despite their marital problems, they had a church wedding on February 22, 1998, where Cynthia was already five months pregnant. According to Ariel, Cynthia's behavior remained unchanged even after their church wedding, as she continued to gossip and pick fights with their neighbors. Ariel also alleged that Cynthia was unfaithful, having affairs with their neighbor Noli and later with Louie. Ariel eventually left their conjugal home after Cynthia threw a knife at him. Ariel filed a petition for the declaration of nullity of their marriage. To support his petition, Ariel presented the psychological evaluation of Dr. Arnulfo Lopez. The evaluation showed that Ariel had an emotionally disturbed personality, but not severe enough to constitute psychological incapacity. It also revealed that Cynthia suffers from Borderline Personality Disorder with Histrionic Personality Disorder Features. The Regional Trial Court of Quezon City denied the petition, finding insufficient evidence of Cynthia's psychological incapacity.

ISSUES:

  1. Whether the marriage between Ariel S. Calingo and Cynthia Marcellana-Calingo is void.

  2. Whether Cynthia Marcellana-Calingo exhibits psychological incapacity.

RULING:

  1. The Court of Appeals declared the marriage between Ariel S. Calingo and Cynthia Marcellana-Calingo null and void. The court found that Cynthia exhibited psychological incapacity based on the assessment conducted by Dr. Arnulfo Lopez, who concluded that Cynthia suffers from Borderline Personality Disorder with Histrionic Personality Disorder Features.

PRINCIPLES:

  • A marriage may be declared null and void if one or both parties exhibit psychological incapacity that renders them unable to fulfill their essential marital obligations.

  • Psychological incapacity refers to a "serious psychological illness afflicting a party even before the celebration of the marriage, which makes the party completely unable to discharge the essential obligations of the marital state."