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SANTOS-HALILI and THE REPUBLIC OF THE PHILIPPINES, Respondents, G.R. No. 165424, June 9, 2009 RESOLUTION CORONA, J.: This resolves the motion for reconsideration of the April 16, 2008 resolution of this Court denying petitioner’s petition for review on certiorari (under Rule 45 of the Rules of Court). The petition sought to set aside the January 26, 2004 decision and September 24, 2004 resolution of the Court of Appeals (CA) in CA-G.R. CV No. 60010. Petitioner Lester Benjamin S. Halili filed a petition to declare his marriage to respondent Chona M. Santos-Halili null and void on the basis of his psychological incapacity to perform the essential obligations of marriage in the Regional Trial Court (RTC), Pasig City, Branch 158. He alleged that he wed respondent in civil rites thinking that it was a “joke.” After the ceremonies, they never lived together as husband and wife, but maintained the relationship. However, they started fighting constantly a year later, at which point petitioner decided to stop seeing respondent and started dating other women. Immediately thereafter, he received prank calls telling him to stop dating other women as he was already a married man. It was only upon making an inquiry that he found out that the marriage was not “fake.” Eventually, the RTC found petitioner to be suffering from a mixed personality disorder, particularly dependent and self-defeating personality disorder, as diagnosed by his expert witness, Dr. Natividad Dayan. The court a quo held that petitioner’s personality disorder was serious and incurable and directly affected his capacity to comply with his essential marital obligations to respondent. It thus declared the marriage null and void. On appeal, the CA reversed and set aside the decision of the trial court on the ground that the totality of the evidence presented failed to establish petitioner’s psychological incapacity. Petitioner moved for reconsideration. It was denied. The case was elevated to this Court via a petition for review under Rule 45. We affirmed the CA’s decision and resolution upholding the validity of the marriage. Petitioner then filed this motion for reconsideration reiterating his argument that his marriage to respondent ought to be declared null and void on the basis of his psychological incapacity. He stressed that the evidence he presented, especially the testimony of his expert witness, was more than enough to sustain the findings and conclusions of the trial court that he was and still is psychologically incapable of complying with the essential obligations of marriage. We grant the motion for reconsideration. In the recent case of Te v. Yu-Te and the Republic of the Philippines, this Court reiterated that courts should interpret the provision on psychological incapacity (as a ground for the declaration of nullity of a marriage) on a case-to-case basis — guided by experience, the findings of experts and researchers in psychological disciplines and by decisions of church tribunals.
He also suffered from partner relational problem during his marriage with Chona. It is a mixed personality disorder from self-defeating personality disorder to [dependent] personality disorder and this is brought about by [a] dysfunctional family that petitioner had.] [T]hey never had a residence. Now. this Court defined dependent personality disorder as [a] personality disorder characterized by a pattern of dependent and submissive behavior. they never consummated the marriage. I don’t think he understood what it meant to really be married and after the marriage. Dayan. At times they actually bring about dominance by others through a quest for overprotection. they fear criticism and are easily hurt by others’ comments. In Te. we emphasized that. the testimony of petitioner’s expert witness revealed that petitioner was suffering from dependent personality disorder. It was a very impulsive decision. Such individuals usually lack self-esteem and frequently belittle their capabilities. going back to the examinations and interviews which you conducted. despite having the primary task and burden of decision-making. Sir. Dr. sir. Can you expound on this? A. Well. xx xx I don’t think they truly appreciate the civil [rites which] they had undergone. there were frequent quarrels and so there might be a problem also of lack of respect [for] each other and afterwards there was abandonment. the petitioner is suffering from a personality disorder. Likewise. what made you conclude that Lester is suffering from psychological incapacity to handle the essential obligations of marriage? A. by the very nature of Article 36. I guess the relationship died a natural death. Now [from] what particular portion of their marriage were you able to conclude xx xx that petitioner and respondent are suffering from psychological incapacity? A. he never lived with the respondent. must consider as essential the expert opinion on the psychological and mental disposition of the parties.Accordingly. During the very short relationship they had. there was no sexual intercourse. xx xx xx Q. you stated here in your evaluation that Lester Halili and respondent suffered from a grave lack of discretionary judgment. xx xx xx Q. courts. In this case. . Q. and he never thought it was a really serious matter at all. And after three months he refused to see or talk with the respondent and afterwards. xx xx they never lived together[. there was no consummation. can you briefly tell this court your findings [and] conclusions? A. [It was] just a spur of the moment decision that they should get married xx xx I don’t think they truly considered themselves married. There were lots of fights and it was not truly a marriage. Thus: Q. for the reason that his motivation for marriage was very questionable.
as expected of persons suffering from a dependent personality disorder. This submissive attitude encouraged other people to take advantage of him. I mentioned awhile ago that Lester’s family is dysfunctional. And so. Dr. in the same Te case. Dr. The father was very abusive. Dr. This Court. . These disorders affect all areas of functioning and. Dayan traced petitioner’s personality disorder to his dysfunctional family life. by his father who treated his family like robots and. Dr. by respondent who was as domineering as his father. and thus therapy may be long-term. very immature and somehow not truly understand[ing] what [it] meant to be a husband. volunteer to do things that are demeaning in order to get approval from other people. may allow others to make most of their important decisions (such as where to live). very domineering. Dayan concluded that petitioner’s personality disorder was grave and incurable and already existent at the time of the celebration of his marriage to respondent. personality disorders are “long-standing. Dayan further observed that.” From the foregoing. They might [have been] x x x given financial support because the father was [a] very affluent person but it was never an intact family. tend to agree with people even when they believe they are wrong. I would say Lester grew up. The mother has been very unhappy and the children never had affirmation. it has been shown that petitioner is indeed suffering from psychological incapacity that effectively renders him unable to perform the essential obligations of marriage. Sir. Petitioner’s mother even had to be the one to tell him to seek legal help when he felt confused on what action to take upon learning that his marriage to respondent was for real. recognized that individuals with diagnosable personality disorders usually have long-term concerns. later. not having self-confidence. have difficulty starting projects or doing things on their own. inflexible ways of behaving that are not so much severe mental disorders as dysfunctional styles of living. When petitioner could no longer take respondent’s domineering ways. feel uncomfortable or helpless when alone and are often preoccupied with fears of being abandoned. It has been sufficiently established that petitioner had a psychological condition that was grave and incurable and had a deeply rooted cause. petitioner typically acted in a self-denigrating manner and displayed a self-defeating attitude. he preferred to hide from her rather than confront her and tell her outright that he wanted to end their marriage. This could be seen in the way petitioner allowed himself to be dominated. to wit: Q. beginning in childhood or adolescence. Ultimately. create problems for those who display them and for others. Particularly. Dayan stated that petitioner’s dependent personality disorder was evident in the fact that petitioner was very much attached to his parents and depended on them for decisions. first. Individuals who have this disorder may be unable to make everyday decisions without advice or reassurance from others. In her psychological report. x x x The wife and the children were practically robots. And what might be the root cause of such psychological incapacity? A.Dependent personality disorder usually begins in early adulthood. what [it] meant to have a real family life. Accordingly. the marriage between petitioner and respondent is declared null and void.
JR. the motion for reconsideration is hereby GRANTED. . CV No. 60010 are SET ASIDE. 2004 decision and September 24. Pasig City..WHEREFORE.* LEONARDO-DE CASTRO and PERALTA. 1998 is hereby REINSTATED. 2008 resolution of this Court and the January 26..R. PUNO. C. VELASCO. The decision of the Regional Trial Court. Chairperson. Branch 158 dated April 17. SO ORDERED. The April 16. 2004 resolution of the Court of Appeals in CA-G. CORONA.J.** JJ.
The motion for reconsideration granted. with the help of psychologist. HALILI AND THE REPUBLIC OF THE PHILIPPINES. 2009. The RTC declared the marriage null and void because they found out that the petitioner suffered a mixed personality disorder. The SC denied the petitioner’s petition for review on certiorari. NO. create problems for those who display them and for others. personality disorders are “long-standing. Corona Facts: This is a resolution for motion for reconsideration which the SC denied the petitioner’s petition for review on certiorari under Rule 45 of Rules of Court. inflexible ways of behaving that are not so much severe mental disorders as dysfunctional styles of living. And the decision of the RTC reinstated. the marriage between petitioner and respondent is declared null and void. existing at the time of marriage. In this case. particularly dependent and self-defeating personality disorder constitutes psychological incapacity? Ruling: The SC has laid down the substantive requirement for psychological incapacity that it must be characterized by gravity. it has been sufficiently established that petitioner had a psychological condition that was grave and incurable and had a deeply rooted cause. individuals with diagnosable personality disorders usually have long-term concerns. Particularly. From the foregoing.defeating personality disorder. The CA reversed the RTC’s decision. Santos-Halili null and void on the basis of his psychological incapacity to perform the essential obligations of marriage. The resolution of CA and SC set aside.R. G. beginning in childhood or adolescence. These disorders affect all areas of functioning and. J. particularly dependent and self. . and thus therapy may be long-term.Petition Granted HALILI v. Jurisprudential statements of the experts. juridical antecedents and incurability. it has been shown that petitioner is indeed suffering from psychological incapacity that effectively renders him unable to perform the essential obligations of marriage. 165424. Halili filed a petition to declare his marriage to respondent Chona M. Petitioner Lester Benjamin S. June 9.Case Brief for Case II. Issue: Does mixed personality disorder. Consequently.
Virtudazo Student Judge Helen Cabatos Legal Research Instructor October 10. 2011 .LEGAL RESEARCH Cases on Psychological Incapacity Harriet T.
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