Valenzuela v. Valenzuela


Valenzuela v. Valenzuela

G.R. No. 254357

April 12, 2023


                Catherine met Juvenal at their common place of work in Taguig City. She was the bar manager while Juvenal was a bartender. They were often together while on duty. Hence, their feelings for each other developed. They both married in civil rights in 2001. In 2004, she discovered that he was having an affair with a workmate. He evaded the issue. After work, he spent his time drinking liquor or gambling with friends. Following a heated argument, she decided to end their relationship. Later, she learned that he was in a relationship with someone else. In 2010, she received a document of Final Decree of Divorce instituted before the Circuit Court for the City of Alexandria, Virginia, USA by Juvenal against Catherine. In 2016, she filed a Petition for Declaration of Nullity of Marriage under Art. 36 of the Family Code on the ground that both of them are psychologically incapacitated. Catherine was found to be suffering from Dependent Personality Disorder with Passive Aggressive Trends which incapacitates her to comply with her marital obligations. Juvenal was found to be suffering from Narcissistic Personality Disorder co-existing with Anti-Social Personality Disorder.


                Whether or not the marriage between Catherine and Juvenal should be declared as void due to psychological incapacity.


                Yes. In the case of Santos v. CA, psychological incapacity must be characterized by 1.) gravity, 2.) juridical antecedence, and 3.) incurability. It should refer to no less than a mental, not merely physical incapacity that causes a party to be truly incognitive of the basic marital covenants that concomitantly must be assumed and discharged by the parties to the marriage. It must be shown that the incapacity is caused by a genuinely serious psychic cause. With regard to the juridical antecedence, parties to a nullity case are still required to prove it because it is an explicit requirement of the law. Art. 36 is clear that the psychological incapacity must be existing at the time of celebration of the marriage, even if such incapacity becomes manifest only after its solemnization. This distinguishes psychological incapacity from divorce. As to incurability, it means that the incapacity is so enduring and persistent with respect to a specific partner and contemplates a situation where the couple’s respective personality structures are so incompatible and antagonistic that the only result of the union would be the inevitable and irreparable breakdown of the marriage. The condition of the parties can be traced back to their psycho-sexual development as individuals and since it had already been engraved in their psyche, it is already deeply seated in their personality development and existent even prior to the celebration of the marriage.

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