Atty. Julius Gregory Delgado
“REPUBLIC VS. JOHN ARNEL AMATA”, G.R. NO. 212971 (NOVEMBER 29, 2022):
SUPREME COURT REVERSES PSYCHOLOGICAL INCAPACITY TRIAL COURT RULING FOR FAILURE TO ADEQUATELY ADDUCE EVIDENCE OF THE REQUISITES OF ARTICLE 36 OF THE FAMILY CODE
This is a case questioning the ruling of Regional Trial Court of Imus, Cavite, Branch 20, as affirmed by the Court of Appeals. The ruling granted respondent John Arnel Amata’s Petition for Declaration of Nullity of Marriage based on Article 36 of the Family Code on the ground of Psychological Incapacity. In this case, respondent Amata and his wife, Haydee N. Amata (Haydee) met at the Pamantasan ng Lungsod ng Maynila and eventually became sweethearts. They decided to get married and blessed with three (3) children. The marriage was blissful at the incipient but turned sour later. Respondent complained that Haydee was too direct, outspoken, and domineering. Their sexual relationship was no longer satisfying because Haydee wants it quick and as if devoid of feelings. They talked about it and Haydee promised to improve. Haydee’s behavior changed but returned two months later. Haydee also became suspicious of respondent because of the affair of the respondent with a lady friend who lived in Iloilo. Haydee always checked his phone upon discovering of the supposed affair. Respondent then packed his things and left their abode staying in a hotel. Respondent returned home but their relationship continued to deteriorate until respondent left for good. Respondent consulted a Clinical Psychologist, Dr. Elena A. Del Rosario, and instituted the Petition for Declaration of Marriage on the ground of Psychological Incapacity.
The Supreme Court restated the requisites of Psychological Incapacity, as a ground to nullify a marriage, i.e., (a) gravity; (b) juridical antecedence; and (c) incurability. Expounding these requisites, incapacity should be grave and serious in a way that the party would be incapable of carrying out the ordinary duties required in marriage; it must be rooted in the history of the party predating the marriage, although manifestations may only emerge after the marriage; and it must be incurable or, even if it were otherwise, the cure would be beyond the means of the party involved.
The Supreme Court held that the trial court’s reliance on the Judicial Affidavit of the Clinical Psychologist on the respondent to establish Psychological Incapacity is not enough to meet the burden of proof required in the dissolution and declaration of nullity of marriage. The Court held:
“As keenly observed by petitioner, the trial court’s ruling is a mere summary of the allegations, testimonies, and pieces of evidence presented by the respondent. The RTC did not make its own factual findings. There was no actual assessment of the allegations made, witnesses presented, and evidence offered that will serve as a basis for its legal conclusion of psychological incapacity.
The trial court relied heavily on the findings and conclusions made by Dr. Del Rosario about the respondent’s psychological incapacity. However, these observations and conclusions are not comprehensive enough to support a conclusion that a psychological incapacity existed and prevented the respondent from complying with the essential obligations of marriage. There was no identification of the root cause of respondent’s Passive-aggressive Personality Disorder with Narcissistic Traits and that it existed at the commencement of the marriage. There was also no discussion of the incapacitating nature of the supposed disorder and how it affected the capacity of respondent in fulfilling his matrimonial duties due to some illness that is psychological in nature.”
The Supreme Court also held that the petitioner in a Petition for Declaration of Nullity of Marriage must show not mere difficulty in performing his duties and functions or unwilling to perform these obligations. The Court held that unsatisfactory marriage is not necessarily a null and void case:
“The foregoing shows that the couple had a normal relationship during the period of their courtship, when they were boyfriend-girlfriend, and even during the first 7 years of their 13-year marriage before the instant petition was filed. They had the occasional misunderstandings which they quickly resolved at the instance of the respondent. Respondent even testified that he is capable of taking good care of his wife and children. There was a momentary falling out during the marriage when respondent allegedly engaged in an affair but the couple eventually reconciled and Haydee even conceived their third child.
Evidently, the totality of these evidence negates any manifestation that respondent was indeed afflicted with psychological disorder that is so grave, permanent, incurable, and existed at the inception of the marriage which incapacitated him to perform his matrimonial duties and obligations. At most, the evidence presented reveals that respondent’s refusal to cohabit with Haydee was because the marriage has become unsatisfactory. The frequent quarrels caused by suspicion of marital infidelity and the consequent sexual dissatisfaction of the respondent were some of the reasons he is now unwilling to assume the essential obligations of marriage. However, an unsatisfactory marriage is not a null and void marriage. And a person’s refusal to assume essential marital duties and obligations does not constitute psychological incapacity.”
Hence, the Supreme Court reversed and set aside the ruling of the trial court as affirmed by the Court of Appeals and dismissed respondent’s Petition for Declaration of Nullity of Marriage for lack of sufficient evidence.