Perry Canlas v. Grace Lozada-Canlas

 

Perry Canlas v. Grace Lozada-Canlas

G.R. No. 250104

April 12, 2023

 

FACTS:

                On October 7, 2005, or roughly 13 months after knowing each other, Perry and Grace were married at the Regional Trial Court of Quezon City. Their marriage was celebrated a day before Grace was scheduled to leave for the United States of America to work. Thus, the newly married couple did not have an opportunity to live together as husband and wife. At first, the distance did not affect their relationship. As months passed, however, their communication started to lessen. After two years, Grace made a short visit to the Philippines. Perry noticed that Grace's disposition drastically changed. After several months, a friend of Grace admitted to Perry that Grace was having an illicit relationship with another man in the US and that they are already living together. After learning this, Perry suffered from depression, hate, and anger. After consulting a lawyer, Perry was advised to undergo a psychological evaluation. He underwent a psychological evaluation conducted by Amelia Zabala-Macapagal who observed that he is one with healthy psychological make-up (sic) and has the psychological capacity to appreciate the essence of his marriage. On the other hand, Grace's assessment, which was based on Perry's interview and his personal observations, revealed that Grace is shown to be incognitive and imperceptive of her marital role because of her underlying personality problem, that is, she has been found to be afflicted with narcissistic personality disorder. It was stated that Grace's psychological incapacity in the marital context is evaluated to be deep[1]seated, permanent, and serious as it is caused by a grave and non-treatable personality disorder. Perry presented as documentary evidence: ( 1) the Certification, dated December 12, 2012, issued by the Punong Barangay of Sta. Teresita, Angeles City; (2) Certificate of Marriage of Perry Joy L. Canlas and Grace M. Lozada; and (3) Psychological Report of Macapagal. During the trial, Perry, Macapagal, and Ethel U. Wong (Ethel), the spouses' former officemate, took the witness stand.

 

ISSUE:

                Whether or not Grace’s psychological incapacity was duly proven.

 

HELD:

                No, Grace’s psychological incapacity was not duly proven. Personality structure consists of "clear acts of dysfunctionality that undermines the family such that the spouse's personality structure must make it impossible for him or her to understand and to comply with his or her essential marital obligations." As early as the case of Marcos v. Marcos, the Court categorically pronounced that the absence of personal examination or interview of the spouse alleged to be psychologically incapacitated does not invalidate the findings of the expert witness. It is no longer required that the root cause of the psychological incapacity be clinically or medically proven by an expert. Notwithstanding the foregoing, and as correctly argued by the OSG, other evidence must still be presented to prove the existence of psychological incapacity. As earlier mentioned, there must be proof of a person's dysfunctional acts or omission that undermines the family as manifested in his or her personality structure. It must be shown that the spouse's personality structure makes it impossible for him or her to understand and comply with his or her essential marital obligations. In Carullo-Padua v. Padua (Padua), the Court held that ordinary witnesses who may have been present in the spouses' lives prior to their marriage and have observed one or both spouses' behavior, past experiences, or environment, would suffice to prove psychological incapacity.

In this case, other than Macapagal' s interview and report, as well as Ethel's testimony, no other witnesses were presented to prove Grace's psychological incapacity. While Ethel, the spouses' former co-worker, was presented before the RTC, her observations failed to shed light on Grace's personality structure, upbringing, and childhood. Ethel's observations grossly fell short to prove Grace's alleged psychological incapacity. Moreover, it bears to stress that Macapagal's interview was solely based on Perry's observations. To recall, however, Perry met Grace in 2004. The two then contracted marriage on October 7, 2005, or roughly 13 months after knowing each other. Thereafter, they never lived together as husband and wife since Grace went to the US. Expectedly, with the short time that the spouses spent together, Perry's observations of Grace's personality structure, upbringing, and childhood could not be that exhaustive. Hence, the totality of evidence presented by Perry failed to meet the quantum of evidence required to annul their marriage on the ground of psychological incapacity.