Tan- Andal v. Andal

G.R. No. 196359, May 11, 2021

Facts:

Mario Victor M. Andal (Mario) and Rosanna L. Tan (Rosanna) married on December 16, 1995, at the Saints Peter and Paul Parish in Poblacion, Makati City.  After four years of marriage, Mario and Rosanna separated in 2000.  On August 6, 2003, Rosanna filed a Petition for a declaration of nullity of her marriage, claiming that Mario was psychologically incapacitated to comply with his essential marital obligations to her.

Rosanna maintains that the Court of Appeals gravely erred in reversing the trial court’s Decision, claiming that the totality of evidence she presented was sufficient to prove Mario’s psychological incapacity. With respect to Dr. Garcia’s findings, Rosanna claims that they are reliable, having been subjected to cross-examination by Mario’s counsel and were based on documents written by Mario himself, among others. Mario maintains that she failed to prove that his past drug use was a manifestation of a personality disorder that rendered him psychologically incapacitated.  Mario argues that his past drug use is, at best, only grounds for legal separation, not for the nullity of marriage due to psychological incapacity. Mario argues that psychological incapacity is truly incurable, which means it is medically or clinically permanent. Rosanna contended that Mario’s drug use was the manifestation of a grave personality disorder “deeply rooted within [Mario’s] adaptive system.”  She thus prayed that the trial court nullifies their marriage and that she be declared the sole and absolute owner of the parcel of land donated to her by her aunt as well as the duplex built on it.  To prove Mario’s psychological incapacity, Rosanna presented Dr. Valentina Del Fonso Garcia (Dr. Garcia), a physician-psychiatrist, as an expert witness.

In its May 9, 2007 Decision, the Regional Trial Court found that Rosanna discharged the burden of proving Mario’s psychological incapacity. The trial court thus voided Mario and Rosanna’s marriage. Reversing the trial court’s ruling and declaring that the marriage is valid and subsisting. The Court of Appeals found Dr. Garcia’s psychiatric evaluation of Mario to be “unscientific and unreliable” since she diagnosed Mario without interviewing him. The Court of Appeals ruled that Dr. Garcia “was working on pure suppositions and second-hand information fed to her by one side.

Issue:

Whether or not the marriage between Mario and Rosanna is void due to psychological incapacity.

Ruling:

Yes, their marriage is void due to psychological incapacity. Article 36 of the Family Code provides that 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 In the case at bar, the Court found that Rosanna proved with clear and convincing evidence that Mario was psychologically incapacitated to comply with his essential marital obligations. Hence, the marriage is void due to psychological incapacity.