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MARIA ELENA BUSTAMANTE DYTIANQUIN v. EDUARDO DYTIANQUIN

FACTS:

Eduardo and Elena were married in 1970 but separated in 1976 due to marital problems. Eduardo filed a petition for the annulment of their marriage, claiming that both parties were psychologically incapacitated to fulfill their marital obligations. He provided a psychological assessment report conducted by Dr. Nedy L. Tayag, which diagnosed him with Passive Aggressive Personality Disorder and Elena with Narcissistic Personality Disorder. The RTC dismissed Eduardo's petition, ruling that there was no evidence of a disordered personality that rendered them incapable of fulfilling their marital duties. However, the CA disagreed and overturned the RTC's decision, declaring the marriage void based on Dr. Tayag's findings that both parties were psychologically incapacitated.

ISSUES:

  1. Whether the Court of Appeals erred in declaring the marriage between Elena and Eduardo void on the ground of psychological incapacity.

  2. Whether the parties' personality disorders amount to psychological incapacity.

  3. Whether the behavior of either party demonstrated a disordered personality that made them completely unable to discharge the essential obligations of a marital state.

  4. Whether the marriage between Eduardo Dytianquin and Maria Elena Bustamante Dytianquin is void on the ground of psychological incapacities.

RULING:

  1. The Court grants the petition. The Court finds that the totality of the evidence presented failed to establish the psychological incapacity of both parties to fulfill their marital obligations. The evidence failed to show that their psychological incapacity was grave, rooted in the history of the parties, and incurable.

  2. The Court found that the totality of the evidence presented failed to prove sufficient factual or legal basis to rule that the parties' personality disorders amount to psychological incapacity under Article 36 of the Family Code. The Court held that the incapacity of Eduardo is premised not on some debilitating psychological condition but rather from his refusal or unwillingness to perform the essential marital obligations. The existence of Elena's Narcissistic Personality Disorder was not sufficiently proven during trial.

  3. The Court determined that there was no showing that the behavior of either party demonstrated a disordered personality which made them completely unable to discharge the essential obligations of a marital state. While the alleged personality disorders of Eduardo and Elena made it difficult for them to comply with their marital duties, it did not make them psychologically incapacitated to fulfill their essential marital obligations.

  4. The petition for review on certiorari is granted. The Court of Appeals' decision declaring the marriage void on the ground of psychological incapacities is reversed and set aside. The petition for declaration of nullity of marriage is dismissed.

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 belongs to the plaintiff. Any doubt should be resolved in favor of the existence and continuation of the marriage and against its dissolution and nullity.

  • 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 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 must be those embraced by Articles 68 up to 71 of the Family Code as regards the husband and wife.

  • The interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines, while not controlling or decisive, should be given great respect by the courts.

  • Mere difficulty, refusal, or neglect in the performance of marital obligations or ill will on the part of the spouse is different from incapacity rooted in some debilitating psychological condition or illness. Irreconcilable differences, sexual infidelity or perversion, emotional immaturity, and irresponsibility do not warrant a finding of psychological incapacity.

  • Psychological incapacity must be more than just a "difficulty," "refusal," or "neglect" in the performance of marital obligations. A mere showing of irreconcilable differences and conflicting personalities does not constitute psychological incapacity under Article 36 of the Family Code.

  • An unsatisfactory marriage is not a null and void marriage. Psychological capacity under Article 36 is not to be confused with a divorce law that cuts the marital bond at the time the causes therefor manifest themselves.

  • A marriage may be declared void if one or both parties have a grave and incurable psychological illness existing at the time of the marriage, rendering them incapable of understanding the obligations of marital life.

  • In order for a marriage to be declared void due to psychological incapacity, the illness must be shown to be grave, incurable, and existing at the time of the marriage ceremony.

  • The burden of proving psychological incapacity rests upon the party alleging it.

  • Every intendment of the law or facts leans toward the validity of marriage, the indissolubility of the marital tie, and the legitimacy of children conceived and born in lawful wedlock.

  • The court must be convinced by the evidence presented that the psychological incapacity is both grave and incurable, and that it exists at the time of the celebration of the marriage.