Viñas vs Viñas

Facts:
In the case at bar, petitioner Glen Viñas filed a petition for the declaration of his marriage with
Mary Grace pursuant to Art. 36 of the Family Code on the ground that his wife was insecure,
extremely jealous, outgoing and prone to regularly resorting to any pretext to be able to leave
the house, she lived as if she was single and unmindful of her husband’s needs.
Presented on trial, a psychologist certified that the respondent was suffering from a Narcissistic
Personality Disorder with anti-social traits and concluded that the parties are not founded on
mutual love, trust, respect, commitment and fidelity to each other.
The RTC declared the marriage between the parties null and void on account of respondent’s
psychological incapacity.
The Office of Solicitor General appealed and claimed that no competent evidence exist proving
that the respondent indeed suffers from a Narcissistic Personality Disorder which prevents her
from fulfilling her marital obligations, specifically the RTC decision failed to cite the root cause of
the respondent’s disorder. The RTC did not state its own findings and merely relied on the
psychologist’s statement.
ISSUE
Whether or not sufficient evidence exist justifying the RTC’s declaration of nullity of petitioner’s
marriage with his wife.
Ruling:
No. The Supreme Court find that the observations and conclusions of the trial court are
insufficiently in-depth and comprehensive to warrant the conclusion that a psychological
incapacity existed that prevented the respondent from complying with the essential obligations
of marriage. It failed to identify the root cause of the respondent’s narcissistic personality
disorder and to prove that it existed at the inception of the marriage. Neither did it explain the
incapacitating nature of the alleged disorder, nor show that the respondent was really incapable
of fulfilling his duties due to some incapacity of a psychological, not physical, nature.
IV. Characteristics of Psychological Incapacity:
Gravity – illness must be serious enough
Juridical Antecedence – rooted in the history of party and proven existing at the time of marriage
although the overt acts are manifested during the marriage or after.
Incurability – shown to be medically or clinically permanently or incurable; absolutely or relative
only to other spouse.
In this case, it failed to identify the characteristics of psychological incapacity. Hence, the
petition was not granted.