Atty. Gregorio B. Austral, CPA
Examining Dependent Personality Disorder (DPD) and Narcissistic Personality Disorder (NPD) as grounds for annulment
Some say that love knows no age while others also say that it’s not that love knows no age since love indeed knows age, but it just doesn’t care. To many, a May-December love affair may be unusual and sometimes challenging. One challenge is when people may say stereotypical things about “cougars,” if the woman is the older partner, or “trophy wives,” if the man is the older partner.
Against all odds, the love affair of Juanita and James Paul successfully prevailed over the name-calling. But later, the age gap seems to have manifested in a form of psychological incapacity. Should the court free them from this entanglement? Let us examine their case.
Sometime in 1999, James Paul met Juanita at a car service center along Marcos Highway, Antipolo City. At that time, Juanita was forty (40) years old and James Paul was twenty-two (22) years old. Juanita became James Paul’s girlfriend, and three (3) months into the relationship, she became pregnant. Eventually, or on March 31, 2000, Juanita and James Paul got married in civil ceremony. During their marriage, however, instead of experiencing marital bliss, their relationship was fraught with quarrels. According to James Paul, Juanita was domineering, considering that she was the one earning and he was a high school drop-out. Sometime in 2005, they separated because they could no longer stand each other. After eleven (11) years of living apart, James Paul filed a Petition for Declaration of Nullity of Marriage.
In support of his petition, James Paul presented the report of an expert clinical psychologist who assessed him to be suffering from Dependent Personality Disorder (DPD), and Juanita from Narcissistic Personality Disorder (NPD). According to the report, James Paul’s DPD is a long-term chronic condition that manifested itself through his overdependence on Juanita and his own mother to meet his emotional and physical needs. The clinical features of his DPD were likewise exhibited through his: (a) difficulty in making everyday decisions without an excessive amount of advice and reassurance from Juanita and his own mother; ( b) problem in expressing disagreement with others because of fear or loss of support or approval; (c) struggle in initiating projects on his own because of lack of self-confidence in judgment or abilities; (d) excessive dependence on Juanita and his own mother to obtain nurturance and support; and (e) inclination to substance use and abuse.
On the other hand, Juanita’s NPD was found to be grave, severe, and already ingrained deeply within her adaptive system, as evidenced by her pervasive pattern of grandiosity, need for admiration, and lack of empathy. As both parties were found to be psychologically incapacitated to perform their essential marital obligations, the psychologist, therefore, recommended that their marriage be declared null and void.
The RTC granted the petition and declared the marriage of the parties null and void on the ground of James Paul’s psychological incapacity. The totality of evidence sufficiently established his incapacity to fulfill his marital obligations, as he was shown to have disregarded and abandoned his family after repeated quarrels with Juanita. Moreover, having been diagnosed with DPD, James Paul manifested his inability to be cognizant of his familial obligations.
The Supreme Court, however, disagreed with the RTC and CA which affirmed the decision.
According to case law, psychological incapacity should be confined to the most serious cases of personality disorders that clearly manifest utter insensitivity or inability to give meaning and significance to the marriage. It should refer to no less than a mental-not merely physical incapacity that causes a party to be truly incognitive of the basic marital covenants·· that concomitantly must be assumed and discharged by the parties to the marriage, which, as provided under Article 6837 of the Family Code, among others, include their mutual obligations to live together, observe love, respect and fidelity, and render help and support.
Applying the foregoing guidelines, the Court finds that – contrary to the rulings of the courts a quo – the totality of evidence presented failed to sufficiently establish James Paul’s psychological incapacity based on his DPD. There is nothing in his acts that is indicative of his ‘chronic condition in which he depends too much on others to meet his emotional and physical needs. In fact, the report failed to show ‘who’ are those other that he depended on too much. Also, James Paul’s alleged DPD appears to be even contrary to his personality since the report actually states, among others, that his “common capacities and strengths” are “being friendly, energetic, resourceful, and having negotiating skills.” (Juanita Cahapisan-Santiago vs. James Paul A. Santiago, G.R. No. 241144, June 26, 2019)