Dedel v. Corpuz-Dedel
REITERATIONFacts
1. The Antecedents: The petitioner and respondent were married in 1966, with a subsequent church wedding in 1967, and had four children. The petitioner alleged that the respondent was an irresponsible wife and mother, engaging in extramarital affairs and exhibiting immaturity and irresponsibility. She was diagnosed with Anti-Social Personality Disorder by a psychiatrist, which the petitioner claimed constituted psychological incapacity to perform marital obligations. The respondent also had two children with another man, Mustafa Ibrahim, whom she later married and then abandoned the petitioner to join again. 2. Procedural History: The petitioner filed a petition for declaration of nullity of marriage based on psychological incapacity with the Regional Trial Court (RTC) of Makati City. The RTC granted the petition, declaring the marriage null and void and dissolving the conjugal partnership. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Court of Appeals. The Court of Appeals reversed the RTC's decision, setting aside the judgment and ordering the dismissal of the petition. The petitioner's motion for reconsideration was subsequently denied. 3. The Petition: The petitioner filed the instant petition for review on certiorari, arguing that the Court of Appeals gravely abused its discretion and manifestly erred in its conclusion that the respondent was not suffering from psychological incapacity. He contended that the appellate court erred in finding that the respondent's psychological incapacity was not attended by gravity, juridical antecedence, and permanence or incurability, and that the evidence presented was insufficient to prove such incapacity. The core issue presented to the Supreme Court was whether the totality of evidence was sufficient to sustain a finding of psychological incapacity, specifically whether the respondent's aberrant sexual behavior fell within the legal definition.
Issue(s)
Whether the totality of the evidence presented is sufficient to sustain a finding that respondent is psychologically incapacitated under Article 36 of the Family Code. Whether the aberrant sexual behavior of respondent falls within the definition of "psychological incapacity." Whether the RTC has jurisdiction to dissolve the church marriage.
Ruling
The petition is DENIED. The decision of the Court of Appeals dismissing the petition for declaration of nullity of marriage is AFFIRMED.
Ratio Decidendi
On whether the totality of the evidence presented is sufficient to sustain a finding that respondent is psychologically incapacitated under Article 36 of the Family Code: The Supreme Court reiterated the ruling in Santos v. Court of Appeals, defining "psychological incapacity" as a mental, not physical, incapacity that causes a party to be truly incognitive of the basic marital covenants. It must refer to the most serious cases of personality disorders clearly demonstrative of an utter insensitivity or inability to give meaning and significance to the marriage, existing at the inception of the marriage. On whether the aberrant sexual behavior of respondent falls within the definition of "psychological incapacity": The Court found that respondent's sexual infidelity or promiscuity and abandonment, while serious, do not by themselves constitute psychological incapacity. These acts must be shown to be manifestations of a disordered personality that makes the respondent completely unable to discharge the essential obligations of the marital state, not merely due to youth, immaturity, or sexual promiscuity. The Court noted that the evidence presented by the petitioner referred to grounds for legal separation under Article 55 of the Family Code, not for declaring a marriage void under Article 36. The Court emphasized that Article 36 is not to be equated with legal separation, where grounds need not be rooted in psychological incapacity. The Court also pointed out that the respondent's alleged promiscuity did not appear to exist prior to or at the inception of the marriage, as the records showed a blissful marital union at its celebration which produced four children. On whether the RTC has jurisdiction to dissolve the church marriage: The Supreme Court agreed with the Court of Appeals that the trial court has no jurisdiction to dissolve the church marriage. The authority to do so is exclusively lodged with the Ecclesiastical Court of the Roman Catholic Church.
Main Doctrine
Sexual infidelity, promiscuity, or abandonment, while grounds for legal separation, do not by themselves constitute psychological incapacity under Article 36 of the Family Code unless they are manifestations of a disordered personality that makes the respondent completely unable to discharge the essential obligations of the marital state.