[PERSONS AND FAMILY RELATIONS] Module 2 (#25)

Topic: Void Marriages (Art. 35-44, Family Code)

Title: Carating-Siayngo v. Siayngo G.R. No. 158896
Ponente: Date October 27, 2004
DOCTRIN
E
/RIGHTS
APPLIED
FACTS Manuel Siayngco filed a petition for the declaration of nullity of his
marriage with Juanita Siayngco on the ground of the latter's
psychological incapacity. In her answer, Juanita contended that it was
respondent Manuel who was remiss in his marital and family
obligations and that she supported Manuel in all his endeavors despite
his philandering. The RTC dismissed Manuel's petition. The CA reversed
the RTC decision.
ISSUE/S Whether or not Juanita/Manuel is psychologically incapacitated to
comply with marital obligations.
RULING No. What emerges from the psychological report is that the only essential
marital obligation which Manuel was not able to fulfil, if any, is the
obligation of fidelity. Sexual infidelity, per se, however, does not constitute
psychological incapacity within the contemplation of the Family Code.

As to the allegation of psychological incapacity on the part of Juanita,

Manuel failed to prove that his wife’s lack of respect for him, her jealousies
and obsession with cleanliness, her outbursts and her controlling nature
(especially with respect to his salary), and her inability to endear herself to
his parents are grave psychological maladies that paralyze her from
complying with the essential obligations of marriage.