IVAN A.

DOMANTAY
1C – PERSONS AND FAMILY RELATIONS

Suazo v. Suazo
G.R. No. 164493
March 10, 2010

TOPIC: Psychological Incapacity

PRINCIPLE : Neglect or refusal to perform marital obligations only indicate difficulty and not
psychological incapacity. Such behaviors must be manifestations of a debilitating psychological condition or
illness for it to be considered as psychological incapacity.

FACTS:
 The relation of Jocelyn M. Suazo (Petitioner) and Angelito Suazo (Respondent) developed as
follows:
o The two met when they were 16 years old in June 1985 at Laguna
o Jocelyn went to Manila with Angelito after months of courtship.
o Their parents brought them back to Laguna and arranged their marriage in March 1986
o After the marriage, they lived with Angelito’s parents. Jocelyn worked odd jobs while
Angelito was drunk for most of the time.
o Jocelyn exerts effort in urging Angelito to find work which often resulted in violent quarrels.
o Jocelyn left Angelito sometime in July 1987 (1 year and 4 months after the marriage)
o Angelito has found and lived with another woman.
 Jocelyn filed a petition to declare the nullity of marriage to the RTC (Regional Trial Court), because
Angelito was psychologically incapacitated to comply with the essential obligations of marriage and
given the historical narrative of their relationship.
 The RTC ruled in favor of Jocelyn and annulled the marriage on the grounds that the evidence
shows that respondent failed to establish a harmonious family life due to respondent’s immaturity,
irresponsibility, drinking habit, and violent tendencies towards her.
 The CA (Court of Appeals) reversed the ruling on the grounds that the evidence was not enough
in relation to the jurisprudence Marcos v. Marcos which asserts that aggregate testimony of the
aggrieved spouse, children and relatives are not sufficient to prove psychological incapacity.
 Jocelyn files another petition to assail the ruling of the CA on the following grounds
o The CA disregarded the jurisprudence “Tuason v. Tuason” which recognizes the finality of
factual findings and;
o Article 36 of the Family Code intentionally did not define psychological incapacity to give
the courts wider discretion on interpretation, but its conditions can be taken from Canon 1095
of the New Code of Canon Law.

ISSUE: W/N the Article 36 of the family code is a basis to nullify the marriage of Jocelyn and Angelito?

RULING: The Court affirmed the decision of the CA and denies the petition for lack of merit.
 Psychologist’s testimony and psychological report did not conclusively show the root cause, gravity,
and incurability of Angelito’s alleged psychological condition.
 Jocelyn’s testimony is insufficient as it only indicates difficulty, negligence, and refusal to do work,
but does not show psychological incapacity.

Note: The Court asserts that is correctly reversed the judgement of the RTC and its ruling in Tuason v Tuason, which recognizes the finality of
factual findings, does not apply in this case.