FACTS:
Restituto and Rosita Alcantara were married in 1976. In 2001, Restituto filed a petition for declaration of nullity of marriage under Article 36 of the Family Code, alleging that Rosita was psychologically incapacitated to perform her marital obligations. He claimed Rosita showed immaturity, irresponsibility, and lack of respect, causing frequent quarrels and abandonment of the family.
The RTC granted the petition, declaring the marriage void. The Court of Appeals reversed, holding that Rosita’s acts were not equivalent to psychological incapacity as contemplated by law. Restituto elevated the case to the Supreme Court.
ISSUE:
Whether Rosita was psychologically incapacitated to warrant the declaration of nullity of marriage under Article 36.
RULING:
No. Rosita was not proven to be psychologically incapacitated.
Psychological incapacity must be grave, antecedent, and incurable, as laid down in Santos v. CA and Republic v. Molina. The evidence merely showed difficulties, immaturity, and irreconcilable differences, which are not equivalent to psychological incapacity. Mere failure, neglect, or refusal to perform marital obligations does not automatically mean incapacity.
The Court affirmed the CA and upheld the validity of the marriage.
DOCTRINE:
Psychological incapacity under Article 36 requires serious mental incapacity existing at the time of the marriage, rendering a spouse incapable of assuming essential marital obligations. Mere stubbornness, immaturity, or marital discord does not constitute psychological incapacity.