Ligeralde v.

Patalinhug

FACTS:

 Silvino and May got married on Oct. 3, 1984 and begot 4 children.
 During their marriage, May manifested several negative marital behaviors such as being
irresponsible immature, and carefree. She even committed infidelity.
 Amidst Silvino’s acts of saving the marriage, May reverted back to her old ways which made
Silvino believe that she is suffering from a psychological illness
 Dr. Basilio: certified that May was psychologically Incapacitated and such incapacity was rooted
in her past, serious, and incurable.
 Silvino filed a complaint

RTC: declared the marriage null and void

CA: Reversed the RTC ruling for such behaviors attributed to May does not constitute psychological
incapacity

ISSUE: WON May is psychologically incapacitated within the contemplation of the Family Code

HELD: NO. The SC ruled that the petitioner’s testimony was not able to prove May’s psychological
incapacity. It was not able to establish the 1) gravity; 2)juridical antecedence; and 3) incurability of
respondent’s psychological incapacity. Petitioner failed to prove that May’s unfaithfulness is a
manifestation of a disordered personality that would hinder her to discharge the essential marital
obligations. SC ruled that such imperfections of the respondent does not warrant a conclusion that she
is psychologically incapacitated to render her incapable of fulfilling her marital and family duties
obligations.

Camacho-Reyes v. Reyes

FACTS:

 Maria Camacho-Reyes and Ramon Reyes met at UP Diliman in 1972 and their frienship quickly
developed into a romantic relationship
 Maria was able to finish college, whereas Ramon dropped out on his 3rd yr.
 On Dec. 1976, after Maria’s graduation, they got married and lived at Ramon’s family where all
of their expenses where shouldered by Ramon’s parents
 Initially, Ramon would give Maria a monthly allowance of 1, 500, but after the birth of their 1st
child on March 1971, it stopped
 Ramon resigned from his job at their family business and started different business ventures.
However, such business ventures were all unsuccessful and took him away from his family,
which fact did not bothered Ramon. The fall of his business ventures also buried them in debt.
 Ramon became distant with Maria that he became unconcerned of her health nor how she
handles their family when he is away.
 On 1996, Maria found out that Ramon was having an affair. Maria made final attempts to
salvage their relationship but to no avail.
  Adolfo, Ramon’s elder brother and his wife invited and sponsored their counselling sessions but
Ramon remained uncooperative. Ramon also resisted and did not continue with the
recommended therapy given by Dr. Dayan, a psychologist.

RTC: Granted the petition for declaration of nullity

CA: Reversed the RTC ruling and declared the marriage valid and subsisting. It ruled that the evidences
failed to prove that incapacity was rooted on a condition.

ISSUE: WON the marriage between the parties are void ab initio under Art. 36

HELD: YES. The marriage is null and void. The lack of personal examination and interview of the
respondent, or any other person diagnosed with personality disorder, does not invalidate the
testimonies of the doctors. Neither do their findings automatically constitute hearsay that would result
in their exclusion as evidence. In the instant case, respondents pattern of behavior manifests an
inability, psychological incapacity, to perform the essential marital obligations.

Baccay v. Baccay

FACTS:

 Noel and Maribel were schoolmates at MAPUA and on 1990, they were introduced to each
other by a mutual friend
 Noel courted Maribel and after years of pursuit, they became sweethearts
 Maribel is a shy, snob, and hard to get kind of girl which appeals to Noel, but sometimes causes
conflict with her attitude towards Noel’s family
 They broke up on 1997, but Maribel insisted to continue seeing each other even if Noel was
already with another woman
 Their “friendship” led to several romantic moments which Noel took as a casual sexual contact
for Maribel never demanded from him
 On Nov. 1998, Maribel told Noel that she was pregnant. Noel grudgingly married Maribel.
 They live with Noel’s family, however Maribel stayed aloof and refused to have sexual contact
with Noel
 Despite Maribel’s claim that she was pregnant, she never showed symptoms of pregnancy that
on Jan. 1999, she did not come home and when she returned, she announced that she had a
miscarriage
 Noel tried to confront her of the issue, but it led into a heated argument. Maribel left the
conjugal home and never came back

RTC: Declared the marriage null and void. Maribel have a Narcissistic Personality Disorder which
hindered her to perform her marital obligations

CA: reversed the ruling of the RTC. Noel failed to establish that Maribel’s disorder is the PI that the law
contemplated

ISSUE: WON the marriage between the parties is null and void under Art. 36
HELD: NO. The marriage is not null and void. The evidence presented were not sufficient to sustain
finding that Maribel was psychologically incapacitated. Noel’s evidence merely established that Maribel
refused to have sexual intercourse with him and that she abandoned him. The disorder also did not
establish how it incapacitated Maribel from validly assuming the essential obligations of marriage.
Refusal to have sexual intercourse is not a ground of psychological incapacity.

Marable v. Marable

FACTS:

 Rosalino and Myrna met in 1967 while studying at Arellano University.

 Dec. 1970, the eloped and married in civil rites at Rizal. They begot 5 children.
 Years passed and their marriage turned sour. Verbal and physical quarrels became common
occurrences
 Rosalino had an affair, but when Myrna learned about it, Rosalino immediately terminated it
 Rosalino left the family home and gave up all his properties which he and Myrna accumulated
during the marriage, in favor of his family
 He converted into islam after dating several woman.
 Oct. 8, 2001, Rosalino filed a petition for declaration of nullity of his marriage
 Dr. Tayag: Rosalino is suffering from Antisocial Personality Disorder

RTC: Annulled the petitioner’s marriage on the ground of his psychological incapacity

CA: Reversed the RTC ruling. Ruled that the circumstances related by the petitioner is insufficient to
establish psychological incapacity

ISSUE: WON the petitioner’s marriage is null and void under Art. 36

HELD: NO. There is no established link between petitioner’s acts to his alleged psychological incapacity.
It appears more likely that he became unfaithful as a result of a general dissatisfaction with his marriage
rather than a psychological disorder rooted in his personal history. Sexual infidelity is not sufficient proof
that the petitioner is suffering from psychological incapacity. It must be shown that the acts of
unfaithfulness are manifestations of a disordered personality which makes petitioner completely unable
to discharge the essential obligations of marriage.

Aurelio v. Aurelio

FACTS:

 Petitioner Danilo and respondent Vida were married on March 23, 1988. They begot 2 sons.
 May 2002, Vida filed a petition for declaration of nullity of marriage alleging that both of them
are psychologically incapacitated of performing and complying with their respective marital
obligations
 Respondent Vida: Histrionic Personality Disorder with Narcissistic features
 Petitioner Danilo: Passive aggressive (Negativistic) Personality disorder
RTC: Granted the declaration of nullity and dismissed Danilo’s motion for reconsideration

CA: Affirmed the RTC decision

ISSUE: WON the marriage is null and void under Art. 36

HELD: YES. The marriage between the parties is null and void. The psychological incapacity of both
parties were expressly provided and it’s 1)gravity; 2) juridical antecedence; and 3) incurability were
sufficiently established. The Court also finds that the essential marital obligations that were not
complied with were alleged in the petition.