REPUBLIC v. ANGELIQUE PEARL O. CLAUR

FACTS:

Angelique Pearl filed a petition for nullity of marriage against Mark, citing psychological incapacity as the ground. She testified that their relationship was plagued by jealousy, obsession, and infidelity, leading to frequent break-ups and physical violence. Despite her parents' disapproval, they got married after she got pregnant. However, she later discovered that Mark had lied about his educational attainment and family background. Their marriage was marked by quarrels, disagreements, and more violence, eventually leading to separation. Angelique Pearl's uncle testified to the tumultuous nature of their marriage.

Angelique Pearl claimed that Mark deceived her into marriage and they lacked responsibility and compatibility. She also stated that Mark engaged in philandering and physically assaulted her, causing severe injuries. Dr. Castillo-Carcereny, a psychiatrist, diagnosed Angelique Pearl with borderline personality disorder and Mark with narcissistic personality disorder, attributing their disorders to dysfunctional families during childhood. The trial court and Court of Appeals granted Angelique Pearl's petition, finding both parties psychologically incapacitated. The OSG sought reconsideration but was denied.

The OSG filed a petition to reverse the decisions, arguing that Angelique Pearl failed to establish psychological incapacity. They claimed that the testimonies were self-serving and lacked substantiation. Angelique Pearl countered that the evidence adequately established psychological incapacity, citing her firsthand experiences and Dr. Castillo-Carcereny's findings based on psychological tests and witness interviews. The OSG argued that personal examination of the alleged incapacitated party was necessary, but Angelique Pearl and Dr. Castillo-Carcereny disagreed, stating that it was not mandatory for the declaration of nullity.

ISSUES:

  1. Did the evidence on record sufficiently support the petition for declaration of nullity of the marriage based on psychological incapacity?

  2. Whether Angelique Pearl and Mark have established the presence of psychological incapacity.

  3. Whether the psychological incapacity of Angelique Pearl and Mark is incurable.

  4. Whether their psychological incapacity renders them unable to fulfill their marital obligations.

  5. Whether the testimony of a medical expert is required to establish psychological incapacity as a legal concept.

  6. Whether the findings of the psychologist based on hearsay evidence are admissible.

  7. Whether there is clear and convincing evidence to support the conclusion that Angelique Pearl and Mark are psychologically incapacitated from complying with their marital obligations.

  8. Whether the marriage between Angelique Pearl and Mark is void ab initio.

RULING:

  1. The totality of evidence on record clearly and convincingly establishes the psychological incapacity of both parties. Article 36 of the Family Code recognizes psychological incapacity as a ground for nullity of marriage. In the case of Tan-Andal v. Andal, it was clarified that psychological incapacity does not require clinical diagnosis and can be proven by ordinary witnesses who have observed the behaviors of the allegedly incapacitated spouse. The gravity and incurability of the incapacity must be established, and juridical antecedence must be proven. The plaintiff-spouse must prove the case by clear and convincing evidence. However, judgments on psychological incapacity cases should be based on the totality of evidence and each case must be resolved on its own merits. The findings of the trial court on psychological incapacity are final and binding unless shown to be clearly erroneous. In this case, the evidence presented clearly and convincingly establishes the psychological incapacity of both parties.

  2. Yes, Angelique Pearl and Mark have established the presence of psychological incapacity. The testimony of Angelique Pearl, as well as her uncle Johnson's testimony, supports the claim of a rocky and violent relationship between the parties even before their marriage. Their dysfunctional acts before and during the marriage have made it impossible for them to understand and comply with their essential marital obligations.

  3. Yes, the psychological incapacity of Angelique Pearl and Mark is incurable. Their respective personality structures were already present before marriage, and their behaviors before and after their wedding clearly manifest their psychological incapacity. Their dysfunctional relationship was not salvaged by their marriage and they are so incompatible and antagonistic towards each other that the only result would be an irreversible breakdown.

  4. Yes, their psychological incapacity renders them unable to fulfill their marital obligations. Their behavior before and after marriage shows their lack of willingness to treat each other as husband and wife. Their dysfunctional relationship, frequent quarrels, physical violence, and lack of love, respect, and fidelity demonstrate their incapacity to fulfill their obligations as spouses and parents.

  5. The Supreme Court declared that the testimony of a medical expert is no longer required to establish psychological incapacity as a legal concept. Courts may now rely on the testimonies of ordinary witnesses to determine whether one or both spouses are psychologically incapacitated.

  6. The Court held that expert opinion based on hearsay evidence can be admitted if the facts are of a type reasonably relied upon by experts in the particular field. The psychologist's findings, based on the information gathered from the spouse and her father, were admissible as they were reasonably relied upon by experts in diagnosing psychiatric disorders.

  7. Yes, there is clear and convincing evidence to support the conclusion that Angelique Pearl and Mark are psychologically incapacitated from complying with their marital obligations.

  8. The marriage between Angelique Pearl and Mark is declared void ab initio.

PRINCIPLES:

  • The totality of the behavior of one spouse during cohabitation and marriage is generally and genuinely witnessed mainly by the other spouse. (Credence given to the personal account of a spouse)

  • Psychological incapacity must satisfy the criteria of juridical antecedence, gravity, and incurability. (Requirements for the declaration of nullity on the ground of psychological incapacity)

  • Physical and verbal abuse, neglect and abandonment of spouse and children, or acts of infidelity including adultery or concubinage, can constitute grounds for legal separation. However, when these grounds collectively manifest psychological incapacity that had been existing even prior to marriage, the marriage may be voided on the ground of psychological incapacity. (Grounds for nullity of marriage)

  • Courts may rely on the testimonies of ordinary witnesses to determine psychological incapacity.

  • The court may admit expert opinion based on hearsay evidence if the facts are reasonably relied upon by experts in the field.

  • Psychological incapacity, in the legal sense, can be a ground for declaring a marriage void.

  • The quantum of evidence required to declare the nullity of marriage must be sufficient and met in the case.

  • The totality of evidence must show that the parties are suffering from grave, permanent, or incurable psychological incapacities with juridical antecedence.

  • Failure to establish a functional family and failure to perform essential marital obligations can be indicative of psychological incapacity.

  • The State aims to preserve marriages characterized by love and respect.