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Petitioner vs. vs. Respondent: Second Division

The Supreme Court of the Philippines ruled to grant the petition to nullify the marriage between Juanita Cahapisan-Santiago and James Paul A. Santiago on the ground of psychological incapacity. The lower courts had found that Santiago suffered from dependent personality disorder (DPD) prior to and during the marriage. However, the Supreme Court found that the evidence was insufficient to prove that Santiago's alleged DPD constituted a psychological incapacity as defined by law - namely, that it was grave, juridically antecedent, and incurable. Therefore, the Supreme Court ruled that the marriage should not be annulled.

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0% found this document useful (0 votes)
196 views6 pages

Petitioner vs. vs. Respondent: Second Division

The Supreme Court of the Philippines ruled to grant the petition to nullify the marriage between Juanita Cahapisan-Santiago and James Paul A. Santiago on the ground of psychological incapacity. The lower courts had found that Santiago suffered from dependent personality disorder (DPD) prior to and during the marriage. However, the Supreme Court found that the evidence was insufficient to prove that Santiago's alleged DPD constituted a psychological incapacity as defined by law - namely, that it was grave, juridically antecedent, and incurable. Therefore, the Supreme Court ruled that the marriage should not be annulled.

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SECOND DIVISION

[G.R. No. 241144. June 26, 2019.]

JUANITA E. CAHAPISAN-SANTIAGO , petitioner, vs. JAMES PAUL A.


SANTIAGO , respondent.

DECISION

PERLAS-BERNABE , J : p

Assailed in this petition for review on certiorari 1 are the Decision 2 dated June 6,
2018 and the Resolution 3 dated August 1, 2018 of the Court of Appeals (CA) in CA-G.R.
CV No. 109683 a rming the Decision 4 dated January 11, 2017 of the Regional Trial
Court of Antipolo City, Branch 72 (RTC) in Civil Case No. 12-9628, which declared the
marriage of petitioner Juanita E. Cahapisan-Santiago (petitioner) and respondent
James Paul A. Santiago (respondent) null and void on the ground of the latter's
psychological incapacity.
The Facts
Sometime in 1999, respondent met petitioner at a car service center along
Marcos Highway, Antipolo City. At that time, petitioner was forty (40) years old and
respondent was twenty-two (22) years old. 5 Petitioner became respondent's girlfriend,
and three (3) months into the relationship, she became pregnant. Eventually, or on
March 31, 2000, petitioner and respondent got married before the Mayor of Pangil,
Laguna. During their marriage, however, instead of experiencing marital bliss, their
relationship was fraught with quarrels. 6
Respondent averred that petitioner was domineering, considering that she was
the one earning and he was a high school drop-out. Sometime in 2005, petitioner and
respondent separated because they could no longer stand each other. After eleven (11)
years of living apart, respondent led a Petition for Declaration of Nullity of Marriage 7
before the RTC. 8 In support of his petition, respondent presented the report 9 of an
expert clinical psychologist, Ms. Shiela Marie O. Montefalcon (Ms. Montefalcon), who
assessed him to be suffering from Dependent Personality Disorder (DPD), 1 0 and
petitioner from Narcissistic Personality Disorder (NPD). 1 1 According to the report,
respondent's DPD is a long term chronic condition that manifested itself through his
overdependence on petitioner and his own mother to meet his emotional and physical
needs. The clinical features of respondent's DPD were likewise exhibited through his:
(a) di culty in making everyday decisions without an excessive amount of advice and
reassurance from petitioner 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-con dence in judgment or
abilities; (d) excessive dependence on petitioner and his own mother to obtain
nurturance and support; and (e) inclination to substance use and abuse. 1 2 On the other
hand, petitioner'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. 1 3 As both parties were found to be
psychologically incapacitated to perform their essential marital obligations, Ms.
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Montefalcon, therefore, recommended that their marriage be declared null and void. 1 4
For her part, petitioner contended that respondent was not psychologically
incapacitated, but was merely immature and lacked a sense of responsibility. 1 5 She
also pointed out that respondent's past addictive behavior is not permanent,
considering that the latter was able to cope with his drug dependency and was able to
change for the better. 1 6 She added that respondent's alleged DPD is even contrary to
his personality, since the report stated that respondent "can present a proposal or lead
a group discussion with ease and tact. He is assertive but sometimes impatient. He is
best in situations that need sound common sense and practical ability with things. He
relies on his ability to improvise instead of preparing in advance." 1 7 Furthermore,
respondent's "common capacities and strengths" are "being friendly, energetic,
resourceful, and having negotiating skills." 1 8 Finally, she claimed that it was
respondent's womanizing, and not his purported dependency, that caused their
frequent fights. 1 9
The RTC Ruling
In a Decision 2 0 dated January 11, 2017, the RTC granted the petition and
declared the marriage of the parties null and void on the ground of respondent's
psychological incapacity. 2 1 The RTC ruled that the totality of evidence su ciently
established respondent's incapacity to ful ll his marital obligations, as he was shown
to have disregarded and abandoned his family after repeated quarrels with petitioner.
2 2 Moreover, having been diagnosed with DPD, respondent manifested his inability to
be cognizant of his familial obligations. 2 3 However, as to petitioner's alleged
psychological incapacity, the RTC held that there was insu cient evidence to prove its
root cause or juridical antecedence. 2 4
Aggrieved, petitioner filed an appeal 2 5 before the CA.
The CA Ruling
In a Decision 2 6 dated June 6, 2018, the CA a rmed the RTC Decision. 2 7 The CA
ruled that respondent was able to discharge his burden of proving that his marriage
with petitioner was void due to his psychological incapacity. 2 8 In this regard, it found
that the root cause of respondent's psychological incapacity, i.e., DPD, was medically
identi ed, and that the same was present at the inception of his marriage with
petitioner, considering that prior to the marriage, he was already irresponsible, drug
dependent, and overdependent on his mother. 2 9 It also found that respondent's DPD
was permanent, incurable, and grave, as a result of his upbringing and family
background.
Dissatis ed, petitioner led a motion for reconsideration, 30 which was denied in
a Resolution 3 1 dated August 1, 2018; hence, this petition.
The Issue before the Court
The issue for the Court's resolution is whether or not the parties' marriage should
be nullified on the ground of respondent's psychological incapacity, i.e., DPD.
The Court's Ruling
The petition is meritorious.
At the outset, it bears stressing that the RTC, as a rmed by the CA, already ruled
that there was insu cient evidence to prove the root cause or juridical antecedence of
petitioner's alleged NPD. Finding no cogent reason to disturb the same, the resolution
of this case shall, thus, revolve on whether or not, on the other hand, respondent's
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psychological incapacity, i.e., DPD, was proven.
Jurisprudence states that the validity of marriage and the unity of the family are
enshrined in our Constitution and statutory laws; hence, any doubts attending the same
are to be resolved in favor of the continuance and validity of the marriage and that the
burden of proving the nullity of the same rests at all times upon the petitioner. The
policy of the Constitution is to protect and strengthen the family as the basic social
institution and marriage as the foundation of the family. As such, the Constitution
decrees marriage as legally inviolable and protects it from dissolution at the whim of
the parties. 3 2
Under Article 36 3 3 of the Family Code, as amended, 3 4 psychological incapacity
is a valid ground to nullify a marriage. However, in deference to the State's policy on
marriage, psychological incapacity does not merely pertain to any psychological
condition; otherwise, it would be fairly easy to circumvent our laws on marriage so
much so that we would be practically condoning a legal subterfuge for divorce. 3 5
According to case law, psychological incapacity should be con ned to the most
serious cases of personality disorders that clearly manifest utter
insensitivity or inability to give meaning and signi cance to the marriage . 3 6 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 68 3 7 of the Family Code, among others, 3 8 include their mutual
obligations to live together, observe love, respect and delity, and render help and
support. 3 9
In this accord, psychological incapacity must therefore be characterized by three
(3) traits: (a) gravity, i.e., it must be grave and serious such that the party would be
incapable of carrying out the ordinary duties required in a marriage; (b) juridical
antecedence, i.e., it must be rooted in the history of the party antedating the marriage,
although the overt manifestations may emerge only after the marriage; and (c)
incurability, i.e., it must be incurable, or even if it were otherwise, the cure would be
beyond the means of the party involved. 4 0
Applying the foregoing guidelines, the Court nds that — contrary to the rulings
of the courts a quo — the totality of evidence presented failed to su ciently establish
respondent's psychological incapacity based on his DPD.
In this case, respondent relied heavily on the testimony of and psychological
examination by the clinical psychologist, Ms. Montefalcon, to establish his
psychological incapacity. In her report, she enumerated several clinical features
indicative of respondent's DPD, to wit: (a) di culty in making everyday decisions
without an excessive amount of advice and reassurance from petitioner 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-con dence in judgment or abilities; (d) excessive dependence on petitioner and his
own mother to obtain nurturance and support; and (e) inclination to substance use and
abuse. 4 1 However, the report leaves much to be desired as it did not even identify
speci c actions or incidents that could amply demonstrate his alleged psychological
incapacity. As the petitioner aptly points out, "[i]n the [p]sychological [r]eport, there is
nothing in [respondent's] 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 [respondent] depended [on] too much x
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x x." 4 2 Also, as petitioner emphasizes, respondent's alleged DPD appears to be even
contrary to his personality since the report actually states, among others, that
respondent's "common capacities and strengths" are "being friendly, energetic,
resourceful, and having negotiating skills." 4 3 Moreover, the report states that
respondent "is best in situations that need sound common sense and practical ability
with things [as] he relies on his ability to improvise instead of preparing in advance." 4 4
More importantly, the link between respondent's acts to his alleged
psychological incapacity was not established. Even if it is assumed that respondent
truly had di culties in making everyday decisions without excessive advice or
reassurance coming from other people, such as petitioner and his own mother, the
report fails to prove that the said di culties were tantamount to serious psychological
disorder that would render him incapable of performing the essential marital
obligations. As case law holds, "[i]n determining the existence of psychological
i nc a p a c i t y, a clear and understandable causation between the party's
condition and the party's inability to perform the essential marital covenants
must be shown . A psychological report that is essentially comprised of mere
platitudes, however speckled with technical jargon, would not cut the
marriage tie." 4 5
Similarly, Ms. Montefalcon's report merely provided general characterizations of
the parties' illnesses as deeply-rooted, grave, and incurable. In her report, she stated
that the root cause of the parties' awed personality patterns was attributable to
genetic factors and/or dysfunctional factors involved in their childhood milieu. She also
declared that their illnesses were grave, since the parties were not able to carry out the
normal and ordinary duties of marriage and family, and incurable, as they have no
psychological insight that they have character problems. 4 6 However, no evidence was
presented to substantiate these conclusions. In fact, as petitioner demonstrates, the
report seems to contradict the foregoing characterizations since it was observed that
respondent "was awaken and decided x x x to x his life" and that "[h]e admitted that he
is weak but he was able to resist drugs and [is now] helping his mother run their
business." 4 7 As such, it cannot be concluded that respondent's DPD is imbued with the
required quality of permanence or incurability.
If anything, Ms. Montefalcon's evaluation only supports the allegations regarding
respondent's in delity, immaturity, and dependence on his mother and wife, which traits
do not, however, rise to the level of the psychological incapacity that would justify the
nulli cation of the parties' marriage. Indeed, while respondent's purported womanizing
caused the couple's frequent ghts, such was not established to be caused by a
psychological illness. In fact, records reveal that when petitioner discovered
respondent's affair for the rst time, the latter immediately severed it. They would also
eventually reconcile and live together after their ghts. Thus, respondent's in delity
does not appear to be a symptom of a grave and permanent psychological disorder
that renders him incapable of performing his spousal obligations. In a long line of
cases, the Court has held that sexual in delity, by itself, is not su cient proof that
petitioner is suffering from psychological incapacity. It must be shown that the acts of
unfaithfulness are manifestations of a disordered personality which make the spouse
completely unable to discharge the essential obligations of marriage. 4 8
In ne, for failing to su ciently prove the existence of respondent's
psychological incapacity within the contemplation of Article 36 of the Family Code, the
petition is granted. The contrary rulings of the courts a quo are hence, reversed and set
aside.
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WHEREFORE , the petition is GRANTED . The Decision dated June 6, 2018 and
the Resolution dated August 1, 2018 of the Court of Appeals in CA-G.R. CV No. 109683
are hereby REVERSED and SET ASIDE . Accordingly, the Petition for Declaration of
Nullity of Marriage led under Article 36 of the Family Code, as amended, is
DISMISSED .
SO ORDERED.
Carpio, Caguioa, J.C. Reyes, Jr. and Lazaro-Javier, JJ., concur.

Footnotes

1. Rollo, pp. 8-28.


2. Id. at 30-45. Penned by Associate Justice Franchito N. Diamante with Associate Justices
Rodil V. Zalameda and Maria Elisa Sempio Diy, concurring.
3. Id. at 46-47.

4. Id. at 48-59. Penned by Judge Ruth C. Santos.


5. See id. at 31, 49, and 84.
6. Id. at 31 and 84-85.

7. Dated March 27, 2012. Records, pp. 1-6.


8. See rollo, p. 32.

9. See Psychological Evaluation Report dated February 15, 2012; id. at 99-110.
10. See id. at 106-107.

11. See id. at 107-108.


12. See id. at 106-107. See also id. at 50-51.
13. See id. at 107. See also id. at 51.

14. See id. at 109.


15. See id. at 16 and 23.

16. See id. at 15-16.


17. See id. at 18 and 106.

18. See id.


19. See id. at 14 and 25. See also id. at 31.
20. Id. at 48-59.

21. Id. at 55 and 58-59.


22. See id. at 56.

23. See id.


24. See id. at 57.
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25. See Brief for the Respondent-Appellant dated December 15, 2017; id. at 64-80.

26. Id. at 30-45.


27. Id. at 44.
28. See id. at 38.

29. See id. at 39-40.


30. Not attached to the rollo.

31. Rollo, pp. 46-47.


32. See Republic v. Tecag, G.R. No. 229272, November 19, 2018.
33. Article 36. A marriage contracted by any party who, at the time of the celebration, was
psychologically incapacitated to comply with the essential marital obligations of
marriage, shall likewise be void even if such incapacity becomes manifest only after its
solemnization.

34. Executive Order No. 227, entitled "AMENDING EXECUTIVE ORDER NO. 209, OTHERWISE
KNOWN AS THE 'FAMILY CODE OF THE PHILIPPINES,'" approved on July 17, 1987.

35. See Republic v. Tecag, supra note 32.


36. See Republic v. Tobora-Tionglico, G.R. No. 218630, January 11, 2018.
37. Article 68. The husband and wife are obliged to live together, observe mutual love, respect
and fidelity, and render mutual help and support.
38. The parties' mutual obligations include those provided under Articles 68 to 71, as regards
the husband and wife, and Articles 220, 221, and 225, with regard to parents and their
children, all of the Family Code. (See Guideline 6 in Republic v. CA, 335 Phil. 664, 678
[1997].)
39. See Republic v. Tecag, supra note 32.

40. See Republic v. De Gracia, G.R. No. 171557, February 12, 2014, 716 SCRA 8, 16, citing
Santos v. CA, 310 Phil. 21, 39 (1995).
41. See rollo, pp. 106-107. See also id. at 50-51.

42. Id. at 18 and 106.


43. Id.
44. Id.
45. See Republic v. Tecag, supra note 32.

46. See rollo, pp. 108-109.


47. Id. at 19.
48. Marable v. Marable, 654 Phil. 529, 539-540 (2011).

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