Case Digest: G.R. No. 167206 November 18, 2005, JAIME F. VILLALON, Petitioner, vs. MA.

CORAZON N. VILLALON, Respondent.

Submitted by: 1C Mascariña, Royce Liane

Facts:

On July 12, 1996, petitioner Jaime F. Villalon filed a petition for the annulment of his marriage to
respondent Ma. Corazon N. Villalon before the Regional Trial Court of Pasig City.

According to petitioner, the manifestations of his psychological incapacity were: (a) his chronic refusal to
maintain harmonious family relations and his lack of interest in having a normal married life; (b) his
immaturity and irresponsibility in refusing to accept the essential obligations of marriage as husband to
his wife; (c) his desire for other women and a life unchained from any spousal obligation; and (d) his false
assumption of the fundamental obligations of companionship and consortium towards respondent.
Petitioner thus prayed that his marriage to respondent be declared null and void ab initio.

On September 25, 1996, respondent filed an answer2 denying petitioner’s allegations. She asserted that
her 18-year marriage to petitioner has been "fruitful and characterized by joy, contentment and hopes for
more growth in their relationship" and that their marital squabbles were normal based on community
standards. Petitioner’s success in his professional life aided him in performing his role as husband, father,
and provider. Respondent claimed that petitioner’s commitment to his paternal and marital
responsibilities was beyond reproach.

The marriage between petitioner and respondent Ma. Corazon N. Villalon was declared null and void ab
initio on the ground of psychological incapacity on the part of the petitioner pursuant to Article 36 of the
Family Code.

Respondent and the OSG filed an appeal from the decision of the trial court, docketed as CA-G.R. CV
No. 74354.

Issue:

Whether or not Mr. Jaime Villalon is psychologically incapacitated to fulfill his marital obligations.

Ruling:

In light of the foregoing, the assailed decision dated November 12, 2001 is REVERSED and SET ASIDE,
and a new judgment entered DISMISSING the petitioner’s petition for lack of merit.

The petitioner filed a motion for reconsideration of the appellate court’s decision; it was DENIED.

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Contrary to the trial court’s findings, the appellate court held that petitioner failed to prove the juridical
antecedence, gravity and incurability of his alleged psychological incapacity. Although Dr. Dayan
testified that petitioner’s psychological incapacity preceded the marriage, she failed to give sufficient
basis for such a finding. Dr. Dayan also stated that parental marital instability was the root cause of
petitioner’s psychological incapacity but failed to elaborate thereon or link the two variables. Moreover,
petitioner’s sexual infidelity was made to appear as symptomatic of a grave psychological disorder when,
in reality, the same merely resulted from a general dissatisfaction with the marriage.

In the case at bar, although Dr. Dayan testified that petitioner suffered from Narcissistic Histrionic
Personality Disorder with Casanova Complex even before the marriage and thus had the tendency to
cheat on his wife, such conclusion was not sufficiently backed by concrete evidence showing that
petitioner indeed had several affairs and finds it difficult to be faithful. Except for petitioner’s general
claim that on certain occasions he had two girlfriends at the same time, no details or explanations were
given of such circumstances that would demonstrate petitioner’s inability to be faithful to respondent
either before or at the time of the celebration of their marriage.

Sexual infidelity, by itself, is not sufficient proof that petitioner is suffering from psychological
incapacity. It must be shown that the acts of unfaithfulness are manifestations of a disordered personality
which make petitioner completely unable to discharge the essential obligations of marriage.

The illness must be shown as downright incapacity or inability, not a refusal, neglect or difficulty, much
less ill will. In other words, there is a natal or supervening disabling factor in the person, an adverse
integral element in the personality structure that effectively incapacitates the person from really accepting
and thereby complying with the obligations essential to marriage.

In the instant case, it appears that petitioner has simply lost his love for respondent and has consequently
refused to stay married to her. As revealed by his own testimony, petitioner felt that he was no longer part
of respondent’s life and that the latter did not need or want him. Respondent’s uncommunicative and
withdrawn nature apparently led to petitioner’s discontentment with the marital relationship.