1

Republic of the Philippines vs.

Martin Nikolai Z. Javier and Michelle K. Mercado-Javier
G.R. No. 210518 | April 18, 2018

FACTS:

On November 20, 2008, Martin Nikolai Z. Javier filed a Petition for Declaration of Nullity
of Marriage, alleging that both he and his wife are psychologically incapacitated to comply with
the essential obligations of marriage. To support their claim, Martin testified on his own behalf,
and presented the psychological findings of one Dr. Elias D. Adamos.

Dr. Adamos likewise diagnosed Michelle with Narcissistic Personality Disorder and
considered the disorder grave and incurable. His informants were Martin and the spouses’
common friend, Jose Vicente Luis Serra. He admitted that he was not able to evaluate Michelle
because the latter did not request to the former’s request for psychological evaluation.

The RTC denied the petition of the spouses. However, upon review in the Court of Appeals,
the instant appeal was granted.

ISSUES:

Whether or not nullity of marriage could be granted to Spouses Javier on the grounds of
psychological incapacity.

RULING:

Yes, the marriage between Martin and Michelle may be declared null and void.

However, the Supreme Court ruled that the petition herein is only partially unmeritorious.

While it is not required for the physician to conduct an actual medical examination on
Michelle, it is evident that Dr. Adamos was not equipped with enough information from which he
may reasonably conclude that Michelle is suffering from a chronic and persistent disorder that is
grave and incurable.

The marriage, therefore, has been declared null and void ab initio not due to Michelle’s
psychological incapacity, but rather due to Martin’s Narcissistic Personality Disorder. Martin’s
disorder affected him in such a manner that he formed unrealistic values and standards on his
own marriage, and proposed unconventional sexual practices that renders him incapable of
fulfilling his essential obligations in their marriage.

Legal Research mfbgarcia