Republic v. Deang
REITERATIONFacts
The Antecedents: Cheryl Pauline R. Deang (Cheryl) and Emilio Z. Deang (Emilio) were married on August 28, 1993. They had one child, Bryan Joseph R. Deang, born on January 12, 1994. The couple met in March 1992 and became romantically involved. Emilio quit his job and engaged in gambling. Cheryl became pregnant in April 1993. Emilio offered to have an abortion, which did not materialize. Cheryl became intimate with Emilio's friend, leading to Emilio's jealousy and physical abuse, including being boxed on the stomach during her second month of pregnancy. They married thereafter. Emilio continued to bring up Cheryl's affair. In January 1994, they returned to Butuan City for Cheryl's delivery. Emilio went to Manila for work. In August 1994, Cheryl visited Emilio in Manila, but he opted for them to live separately. Cheryl discovered Emilio with a mistress. She returned to Butuan City in December 1994 and never saw Emilio again. Procedural History: On February 11, 2013, Cheryl filed a petition for declaration of nullity of marriage before the Regional Trial Court (RTC) of Butuan City, Branch 1, alleging Emilio's psychological incapacity. She claimed Emilio failed to provide support and was living with another woman with whom he had two children. Emilio failed to file an answer or appear during trial. The RTC, giving weight to the psychological evaluation report of Dr. Yolanda Y. Lara, declared the marriage void ab initio due to Emilio's psychological incapacity. The Republic of the Philippines, through the Office of the Solicitor General, appealed to the Court of Appeals (CA). The CA affirmed the RTC's ruling, holding that even without the psychological findings, the events pointed to Emilio's psychological incapacity. The CA also found Cheryl to be suffering from Dependent Personality Disorder (DPD) based on Dr. Lara's findings. The Republic's motion for reconsideration was denied. The Petition: The Republic filed a petition for review on certiorari before the Supreme Court, assailing the CA's decision.
Issue(s)
Whether the Court of Appeals erred in upholding the Regional Trial Court's ruling declaring the marriage between Cheryl and Emilio void pursuant to Article 36 of the Family Code, specifically regarding the establishment of psychological incapacity. Whether the evidence presented, including Dr. Lara's report, sufficiently established the psychological incapacity of either or both parties, considering the criteria of gravity, juridical antecedence, and incurability, and demonstrating a causal link to the inability to perform essential marital obligations, to warrant a declaration of nullity of marriage under Article 36 of the Family Code.
Ruling
The petition is meritorious. The Decision dated May 30, 2017 and the Resolution dated December 12, 2017 of the Court of Appeals in CA-G.R. CV No. 04183-MIN are REVERSED and SET ASIDE. Accordingly, the petition for declaration of nullity of marriage filed under Article 36 of the Family Code, as amended, is DISMISSED.
Ratio Decidendi
On the issue of psychological incapacity under Article 36 of the Family Code: The Court reiterated that psychological incapacity, as a ground to nullify marriage, must refer to serious personality disorders demonstrative of an utter insensitivity or inability to give meaning and significance to the marriage. It must be a mental incapacity, not merely physical, that causes a party to be incognitive of the basic marital covenants, such as living together, mutual love, respect, fidelity, and rendering mutual help and support. The Court emphasized that this incapacity must be grave and permanent, depriving one of awareness of the duties and responsibilities of the matrimonial bond. On the evidence presented and the basis of Dr. Lara's report: The Court found that the actuations of Emilio and Cheryl were not proven to have existed prior to or at the time of the marriage and could be attributed to factors other than a grave psychological condition. The Court found Dr. Lara's findings regarding Emilio's Anti-Social Personality Disorder (APD) to be solely based on biased narrations, lacking sufficient corroborating evidence or proof of juridical antecedence. The Court stressed that a clear and understandable causation between the party's psychological condition and their inability to perform essential marital covenants must be shown. A psychological report composed of mere platitudes is insufficient to sever the marital tie. The Court concluded that the report failed to demonstrate the relation of the purported disorders to the parties' ability to perform their essential marital obligations, and thus, the marriage could not be declared void ab initio on the ground of psychological incapacity. The Court restated the Santos criteria: (a) gravity, (b) juridical antecedence, and (c) incurability. The Court clarified that emotional immaturity, irresponsibility, or sexual promiscuity do not by themselves constitute psychological incapacity unless rooted in a psychological illness contemplated by Article 36.
Main Doctrine
The Court reiterated that psychological incapacity under Article 36 of the Family Code must be characterized by gravity, juridical antecedence, and incurability, and that mere emotional immaturity, irresponsibility, or sexual infidelity do not by themselves warrant a finding of psychological incapacity unless rooted in a psychological illness. The Court also emphasized the need for a clear and understandable causation between the party's condition and the inability to perform essential marital obligations, with findings not solely based on hearsay or biased accounts.