G.R. No.

196359, May 11, 2021

Andal vs. Andal
Facts: In 1995, Rosanna L. Tan-Andal (Rosanna), petitioner, and Mario Victor M. Andal
(Mario), respondent married each other and was blessed with only one child, Ma. Samantha T.
Andal (Samantha). Earlier in their marriage, Rosanna observed Mario to be emotionally
immature, irresponsible and psychologically imbalanced as a result of excessive consumption of
drugs which pushed Rosanna to make Mario be confined in a drug rehabilitation numerous
time. In December 2000, tired of everything about Mario, Rosanna chose to live separately from
him and in August 2003, Rosanna filed a petition before the RTC to have her marriage be
declared void on the ground that Mario was psychologically incapacitated to perform the
essential marital obligations caused by his addiction to drugs as proven by a psychologist (Dr.
Garcia), who, after interviewing Rosanna, Samantha and Rosanna’s sister, concluded that Mario
is suffering from Narcissistic Antisocial Personality Disorder, thus, indeed incapacitated to
perform his marital obligations. The Regional Trial Court in its decision declared the marriage
between spouses Rosanna and Mario void ab initio as it ruled that Rosanna was able to prove
her case, which prompted Mario to file an appeal before the Court of Appeals. The Court,
however, reversed the trial court on the ground that the findings of Dr. Garcia was
unscientific and unreliable because she diagnosed Mario without interviewing him, hence, this
appeal.

Issue/s: Whether or not the marriage between spouses Rosanna and Mario is void ab initio.

Ruling: Yes. Supreme Court held that the marriage of spouses Rosanna and Mario is ab initio
due to Mario’s psychological incapacity to perform essential marital obligations to Rosanna and
his family.
As the Supreme Court reiterated psychological incapacity consists of clear acts of
dysfunctionality that show a lack of understanding and concomitant compliance with one’s
essential marital obligations due to psychic causes. It is not a medical illness that has to be
medically or clinically identified; hence, expert opinion is not required. As an explicit
requirement of the law, the psychological incapacity must be shown to have been existing at the
time of the celebration of the marriage, and is caused by a durable aspect of one’s personality
structure, one that was formed before the parties married. Furthermore, it must be shown to be
caused by a genuinely serious psychic cause. To prove psychological incapacity, a party must
present clear and convincing evidence of its existence.