DAVID B. DEDEL vs. CA & SHARON L.

CORPUZ-DEDEL
GR. No. 151867 January 29, 2004

FACTS:
● David Dedel and Sharon Corpuz were married on September 28, 1996 and May 20,
1967 in a civil and church wedding, respectively.

● They had four children. David instituted a case for the nullity of their marriage on account
of Sharon’s psychological incapacity to perform basic marital obligations. He claimed
that Sharon had extra-marital affairs with several men including a dentist in the AFP, a
lieutenant in the Presidential Security Command, and a Jordanian national.

● Despite the treatment by a clinical psychiatrist, Sharon did not stop her illicit relationship
with the Jordanian, whom she married and with whom she had two children. When the
Jordanian national left the country, Sharon returned to David bringing along her two
children by the Jordanian national.

● David accepted her back and even considered the illegitimate children as his own.
However, Sharon abandoned David to join the Jordanian national with her two children.
Since then, Sharon would only return to the country on special occasions.

● Dra. Natividad Dayan testified that she conducted a psychological evaluation of David
and found him to be conscientious, hardworking, diligent, a perfectionist who wants all
tasks and projects completed up to the final detail and who exerts his best in whatever
he does.

● On the other hand, Dra. Dayan declared that Sharon was suffering from Antisocial
Personality Disorder exhibited by her blatant display of infidelity; that she committed
several indiscretions and had no capacity for remorse, even bringing with her the two
children of the Jordanian to live with David.

● Such immaturity and irresponsibility in handling the marriage like her repeated acts of
infidelity and abandonment of her family are indications of the said disorder amounting to
psychological incapacity to perform the essential obligations of marriage.

● The trial court declared their marriage null and void on the ground of the psychological
incapacity of Sharon to perform the essential obligations of marriage. While the Court of
Appeals set aside the trial court’s judgement and ordered the dismissal of the petition.
David’s motion for reconsideration was denied. Hence, he appealed to the Supreme
Court.

ISSUE:
Whether or not Sharon’s infidelity is equivalent to psychological incapacity.

RULING:
No. Sharon’s infidelity is not equivalent to psychological incapacity. As held in Santos vs. Court of
Appeals, “psychological incapacity” should refer to no less than a mental, not 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 so expressed in Article 68 of the
Family Code, include their mutual obligations to live together, observe love, respect and fidelity and
render help and support. The law intended to confine the meaning of “psychological incapacity” to the
most serious cases of personality disorders clearly demonstrative of an utter insensitivity of inability to
give meaning and significance to the marriage.

Sharon’s sexual infidelity or perversion and abandonment do not by themselves constitute

psychological incapacity within the contemplation of the Family Code. Neither could her emotional
immaturity and irresponsibility be equated with psychological incapacity. It must be shown that these
acts are manifestations of a disordered personality, which makes the respondent completely unable to
discharge the essential obligations of the marital state, not merely due to her youth, immaturity or
sexual promiscuity.

At best, the circumstances relied upon by David are grounds for legal separation under Article 55 of the
Family Code not for declaring a marriage void. The grounds for legal separation, which need not be
rooted in psychological incapacity, include physical violence, moral pressure, civil interdiction, drug
addiction, habitual alcoholism, sexual infidelity, abandonment, and the like. Decision affirmed. Petition
denied.