LIGERALDE v. PATALINGHUG No. 168796 April 15, 2010 MENDOZA, J.

: Procedural History: This petition seeks to set aside the Decision of the Court of Appeals (CA) which reversed the Decision of the Regional Trial Court of Dagupan City (RTC) declaring the marriage between petitioner Silvino A. Ligeralde (Silvino) and private respondent May Ascension A. Patalinghug (May) null and void. Statement of Facts: The couple wed on October 3, 1984, and begot four children. Silvinio, who described May as immature, irresponsible and carefree, claimed that even before marriage he already noticed some signs of negative marital behavior. During their marriage, he caught her in moments of infidelity, as she would cover up her trysts with her Palestinian boyfriend by saying that she watched a video program in a neighboring town. They would also have alterations despite his pleas of her changing her ways. Despite May's attempt of reformation for the sake of their marriage and children, she still bounced back to her old ways of infidelity, negligence and nocturnal activities, thus leading Silvinio to filing a complaint of psychological incapacity on the part of his wife. Issue: Whether May is psychologically incapacitated to comply with the essential obligations of marriage. Answer: No, the Court’s considered view that petitioner’s evidence failed to establish respondent May’s psychological incapacity characterized by gravity, juridical antecedence and incurability. Reasoning: The facts of petitioner were not sufficient to prove the root cause, gravity and incurability of private respondent’s condition. Even with the testimony of the psychologist, Dr. Nicdao-Basilio, the root cause of psychological incapacity was not identified, as the illness should be fully explained in the totality of evidence of the incapacitating nature. In addition, the private acts of living an adulterous life does not rise to the level of the “psychological incapacity” that the law requires. There must be a manifestation of a disordered personality, which makes her completely unable to discharge the essential obligations of the marital state, not just character flaws that warrant a conclusion of psychological malady. Holding: Petition is denied.

She was said to been having this disorder since her adolescence. Patac’s Psychiatric Evaluation Report fell short in proving that the respondent was psychologically incapacitated to perform the essential marital duties. thus. In 2001. whereby they begot four children. He . He also claimed that she refused to have sex with him because she became very close to a male border of their house. as well as Dr. who claimed that Erlinda is suffering from a Personality Disorder (Mixed Personality Disorder). Reasoning: The court held that both Enrique's court testimony. presented testimonial and documentary evidence to substantiate his claims through the psychiatric evaluation report of Dr. Enrique. the totality of evidence presented failed to establish the respondent’s psychological incapacity. consulted a witch doctor in order to bring him bad fate. however. petitioner filed a petition for the declaration of nullity of marriage on the basis of respondent's psychological incapacity. The petitioner. Juan Cirilo L.: Procedural History: Petitioner Enrique Agraviador y Alunan (Enrique) challenges the resolution of the Court of Appeals (CA) which reversed the resolution of the Regional Trial Court (RTC) Muntinlupa City. and later on became sweethearts after courtship. and refused to use the family name Agraviador in her activities. and even caught their love notes and trysts. with no definite treatment for her disorder. However. Issue: Whether there is basis to nullify the petitioner’s marriage to the respondent on the ground of psychological incapacity to comply with the essential marital obligations. 2010 BRION. motion was denied. J. alleging that she was carefree and irresponsible.” in the performance of some marital obligations that characterize some marriages to the level of psychological incapacity that the law requires. Answer: No. stayed away from their house for long periods of time. Statement of Facts: In 1971.” if not outright “refusal” or “neglect. had an affair with a lesbian. They soon entered into a common-law relationship. but later contracted marriage in 1973. and refused to do household chores like cleaning and cooking. petitioner's claims should be distinguished from the “difficulty. AMPARO-AGRAVIADOR No. did not take care of their sick child to the point of his death. expressed their apprehensions because Erlinda came from a broken family and because of the nature of her work. because the root cause of her psychological incapacity was not medically identified and alleged in the petition. then a security guard. Enrique's family. Patac. 170729 December 8. First. declaring the marriage of the petitioner and respondent Erlinda Amparo-Agraviador (Erlinda) null and void on the ground of the latter’s psychological incapacity. first met Erlinda at a beerhouse where the latter worked.AGRIAVIADOR v.

” and “refused to reform” are insufficient to establish a psychological or mental defect that is serious.” It did not discuss the concept of mixed personality disorder. and how it incapacitated her to comply with the duties required in marriage. The report that he submit likewise failed to prove the gravity or seriousness of the respondent’s condition. cause. Second. its classification. with costs against petitioner. Patac failed to clarify the circumstances that led the respondent to act the way she did in her attempt to establish the juridical antecedence of the respondent’s condition. symptoms. as his enumeration of the respondent’s purported behavioral defects (as related to him by third persons).merely showed that Erlinda had some personality defects that showed their manifestation during the marriage. and failed to show how and to what extent the respondent exhibited this disorder in order to create a necessary inference that the respondent’s condition had no definite treatment or is incurable.. The Psychiatric Evaluation Report likewise failed to adequately explain how Dr.e. Dr. i.” “does not want to change. . There was no other statement regarding the degree of severity of the respondent’s condition. grave. and cure. Patac came to the conclusion that the respondent’s personality disorder had “no definite treatment. his testimony sorely lacked details necessary to establish that the respondent’s defects existed at the inception of the marriage. Holding: Decision and resolution of CA is affirmed. or incurable as contemplated by Article 36 of the Family Code. and petition is denied. and on this basis characterized the respondent to be suffering from mixed personality disorder deemed insufficient. His claims that Erlinda “does not accept her fault. why and to what extent the disorder is grave.

Reasoning: Noel failed to prove the root cause of the alleged psychological incapacity and establish the requirements of gravity. the two lived in Noel's family in Quezon City. Answer: No. JR. who concluded that Maribel was suffering from Narcissistic . BACCAY No. In addition. 2010 VILLARAMA. J: Procedural History: This petition seeks to review the Resolution of the Court of Appeals (CA). which declared the marriage of petitioner Noel B. The two became good friends. 173138 December 1. but Maribel would remain invariably aloof or snobbish and never tried to get close to any family member despite her promise to do so. Noel confronted her about the said miscarriage the next month and the discussion escalated into an intense quarrel. during all the time Maribel lived there. which made Maribel leave the household and never return.BACCAY v. As correctly observed by the CA.. Maribel rejected his efforts. She also refused to contribute to the family's coffer and to have sexual contact with Noel. the totality of evidence presented by Noel was not sufficient to sustain a finding that Maribel was psychologically incapacitated. she remained aloof and did not make an effort to endear herself to them. despite her claims of being pregnant. Issue: Whether the marriage between the parties is null and void under Article 36 of the Family Code. Statement of Facts: In 1990. the report of the psychologist. Baccay (Noel) and Maribel Calderon-Baccay (Maribel) void on the ground of psychological incapacity under Article 36 of the Family Code of the Philippines. After the marriage. which reversed the Decision of the Regional Trial Court (RTC) of Manila. a mutual friend introduced Noel and Maribel when they were both still schoolmates at the Mapua Institute of Technology. it was only after years of continuous courtship that Maribel accepted Noel’s proposal and the two became sweethearts. juridical antecedence. but she refused and offered to accept the relationship as long as they would not break ties. Sometime in September of 1998. In 1997 Noel tried to break the relationship with Maribel because he became involved with another woman. however. however. Noel would bring Maribel to their house to attend family gatherings and other festive occasions. Maribel informed Noel that she was pregnant with his child and upon advice of his mother. there were no observed symptoms of pregnancy. Then sometime in January of 1999. Despite efforts to keep meetings strictly friendly. he reluctantly agreed to marry Maribel on November that same year. she announced to Noel and his family that she had a miscarriage and was confined during the day she was not at home. Despite Noel's efforts to communicate. the two had several episodes of casual sexual contracts. and incurability.

The same psychologist even testified that Maribel was capable of entering into a marriage except that it would be difficult for her to sustain one. Holding: The decision of the CA is affirmed and upheld.Personality Disorder traceable to her experiences during childhood. did not establish how the personality disorder incapacitated Maribel from validly assuming the essential obligations of the marriage. . petition is denied with costs against petitioner. Mere difficulty is not the incapacity contemplated by law.

Sign up to vote on this title
UsefulNot useful

Master Your Semester with Scribd & The New York Times

Special offer for students: Only $4.99/month.

Master Your Semester with a Special Offer from Scribd & The New York Times

Cancel anytime.