This case involved a petition for annulment of marriage based on psychological incapacity of the respondent. The court denied the petition, finding that the petitioner failed to establish three key elements: 1) The petitioner failed to prove the root cause and existence of psychological incapacity at the time of marriage. 2) The petitioner did not establish that the alleged narcissistic personality disorder was permanent and incurable. 3) The respondent's traits and refusal to have sexual intercourse constituted only mild peculiarities, not psychological incapacity as defined by law. The court emphasized that the burden was on proving that an incurable psychological disorder rendered the respondent truly unable to understand basic marital obligations.
This case involved a petition for annulment of marriage based on psychological incapacity of the respondent. The court denied the petition, finding that the petitioner failed to establish three key elements: 1) The petitioner failed to prove the root cause and existence of psychological incapacity at the time of marriage. 2) The petitioner did not establish that the alleged narcissistic personality disorder was permanent and incurable. 3) The respondent's traits and refusal to have sexual intercourse constituted only mild peculiarities, not psychological incapacity as defined by law. The court emphasized that the burden was on proving that an incurable psychological disorder rendered the respondent truly unable to understand basic marital obligations.
This case involved a petition for annulment of marriage based on psychological incapacity of the respondent. The court denied the petition, finding that the petitioner failed to establish three key elements: 1) The petitioner failed to prove the root cause and existence of psychological incapacity at the time of marriage. 2) The petitioner did not establish that the alleged narcissistic personality disorder was permanent and incurable. 3) The respondent's traits and refusal to have sexual intercourse constituted only mild peculiarities, not psychological incapacity as defined by law. The court emphasized that the burden was on proving that an incurable psychological disorder rendered the respondent truly unable to understand basic marital obligations.
NO PSYCHOLOGICAL INCAPACITY The totality of evidence presented by petitioner was not sufficient to sustain a finding that respondent was psychologically incapacitated. Juridical Antecedence: Failed to prove the root cause of alleged psychological incapacity. Maribels refusal to have sexual intercourse with Noel did not constitute a ground to find her psychologically incapacitated under Article 36 of the Family Code. As Noel admitted, he had numerous sexual relations with Maribel before their marriage. Maribel therefore cannot be said to be incapacitated to perform this particular obligation and that such incapacity existed at the time of marriage. Incurability: Failed to establish that the Narcissistic Personality Disorder is permanent and incurable. Petitioner failed to establish that Maribels supposed Narcissistic Personality Disorder was the psychological incapacity contemplated by law and that it was permanent and incurable. The psychologist even admitted that Maribel was capable of entering into marriage except that it would be difficult for her to sustain one. Gravity: Only mild peculiarities in character. Maribels refusal to have sexual intercourse with Noel did not constitute psychological incapacity. As her traits were merely mild peculiarities in her character or signs of ill-will and refusal or neglect to perform her marital obligations. As pointed out by the OSG the psychologist was vague as to how Maribels refusal to have sexual intercourse with Noel constituted Narcissistic Personality Disorder. The CA noted that Maribel may have failed or refused to perform her marital obligations but such did not indicate incapacity. The CA stressed that the law requires nothing short of mental illness sufficient to render a person incapable of knowing the essential marital obligations. Courts Ruling: As correctly observed by the CA, the report of the psychologist, who concluded that Maribel was suffering from Narcissistic Personality Disorder traceable to her experiences during childhood, did not establish how the personality disorder incapacitated Maribel from validly assuming the essential obligations of the marriage. Indeed, the same psychologist even testified that Maribel was capable of entering into a marriage except that it would be difficult for her to sustain one. Mere difficulty, it must be stressed, is not the incapacity contemplated by law. The Court emphasizes that the burden falls upon petitioner, not just to prove that private respondent suffers from a psychological disorder, but also that such psychological disorder renders her truly incognitive of the basic marital covenants that concomitantly must be assumed and discharged by the parties to the marriage. Psychological incapacity must be more than just a difficulty, a refusal, or a neglect in the performance of some marital obligations. An unsatisfactory marriage is not a null and void marriage.