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This document summarizes a Supreme Court case from the Philippines regarding the annulment of a marriage due to psychological incapacity. The petitioner filed for annulment after 35 years of marriage, claiming her husband suffered from dependent personality disorder as diagnosed by a psychiatrist. However, the court ruled that the evidence did not prove psychological incapacity as defined by Article 36 of the Family Code. Specifically, the court found that (1) all marriages experience difficulties but this did not prove true inability to commit to marriage, and (2) the respondent supported the family for 35 years without major issues, so his actions did not demonstrate a psychological abnormality preventing the duties of marriage. Therefore, the petition for annulment was denied.
This document summarizes a Supreme Court case from the Philippines regarding the annulment of a marriage due to psychological incapacity. The petitioner filed for annulment after 35 years of marriage, claiming her husband suffered from dependent personality disorder as diagnosed by a psychiatrist. However, the court ruled that the evidence did not prove psychological incapacity as defined by Article 36 of the Family Code. Specifically, the court found that (1) all marriages experience difficulties but this did not prove true inability to commit to marriage, and (2) the respondent supported the family for 35 years without major issues, so his actions did not demonstrate a psychological abnormality preventing the duties of marriage. Therefore, the petition for annulment was denied.
This document summarizes a Supreme Court case from the Philippines regarding the annulment of a marriage due to psychological incapacity. The petitioner filed for annulment after 35 years of marriage, claiming her husband suffered from dependent personality disorder as diagnosed by a psychiatrist. However, the court ruled that the evidence did not prove psychological incapacity as defined by Article 36 of the Family Code. Specifically, the court found that (1) all marriages experience difficulties but this did not prove true inability to commit to marriage, and (2) the respondent supported the family for 35 years without major issues, so his actions did not demonstrate a psychological abnormality preventing the duties of marriage. Therefore, the petition for annulment was denied.
G.R. No. 184063 January 24. 2011 Facts: Petitioner Cynthia E. Yambao and respondent Patricio E. Yambao married on December 21, 1968. On July 11, 2003, after 35 years of marriage and three children raised into adulthood, petitioner filed a petition before the Regional Trial Court, Makati City, praying the marriage be declared null and void due to her husbands psychological incapacity pursuant to Article 36 of the Family Code. Petitioner claims that her marriage is marred by bickering, quarrels and recrimination because of the respondents difficulty to find a stable job, failure in the family business, refusal to change childrens diapers while petitioner was still recovering from her Caesarean operation, insecurity and jealousy towards acquaintances and relatives, eating and sleeping all day, gambling, and threats to kill her. She then consulted with a psychiatrist who concluded that the respondent suffered from Dependent Personality Disorder. On February 9, 2007, the Regional Trial Court dismissed the petition for lack of merit. On April 16, 2008, the Court of Appeals affirmed the Regional Trial Courts Decision; hence, this petition for review before the Supreme Court. Issue: Whether or not the totality of petitioners evidence establishes the respondents psychological incapacity to perform the essential obligations of marriage. Ruling: No. Though there are existing antecedents, assumptions, predilections, or generalizations, this case must be treated uniquely, given its facts and idiosyncrasies. For marriage to be annulled under Article 36 of the Family Code, it must be proven that the incapacitated spouse manifested mental, not physical, incapacity causing him or her to be truly incognitive of the basic marital covenants. The spouse must suffer from a mental incapacity so severe that he is and becomes unaware of his marital and familial obligations. Psychological incapacity must be judged according to: (a) gravity, (b)juridical antecedence, and (c) incurability.
Article 36 considers incapacity or inability to take cognizance
of and to assume basic marital obligations as totally different from mere difficulty, refusal, neglect or ill will in the performance of marital obligations. Incapacity is defined as: (a) true inability to commit oneself to the essentials of marriage; (b)this inability to commit oneself must refer to the essential obligations of marriage: the conjugal act, the community of life and love, the rendering of mutual help, the procreation and education of offspring; and (c) the inability must be tantamount to a psychological abnormality. All marriages go through bickerings, quarrels and recrimination and rough patches. In this case, the respondent may not be the ideal husband for petitioners exacting standards but they have gone through 35 years of marriage and have raised 3 children into adulthood without any major parenting problems. Moreover, respondent never committed infidelity or physically abused the petitioner or their children. These facts do not prove psychological incapacity.