Cayabyab-Navarrosa vs. Navarrosa

Psychological incapacity under Article 36 of the Family Code is a legal, not a medical, concept, and it is not a mental incapacity or a personality disorder that must be proven through expert opinion; rather, it is a party's genuine inability to comprehend and comply with their essential marital obligations, which can be established by clear and convincing evidence of their dysfunctional behavior during the marriage, even without a formal psychological diagnosis of the incapacitated spouse.

Petitioner Lovelle Shelly S. Cayabyab-Navarrosa and respondent Mark Anthony E. Navarrosa met in 2001 and became lovers. In 2004, they moved to Singapore to work. After the petitioner became pregnant, they returned to the Philippines and married on August 15, 2006. The respondent had lost his job prior to the wedding, making the petitioner the sole provider. The marriage quickly deteriorated due to the respondent's financial irresponsibility, emotional and verbal abuse, and eventual abandonment of the petitioner and their child in August 2007, prompting the petitioner to file for the nullity of their marriage.

• Petitioner and respondent married on August 15, 2006, after petitioner became pregnant; respondent was jobless at the time, and petitioner shouldered all expenses.
• After returning to Singapore post-wedding, respondent exhibited problematic behaviors, including turning off his phone when out, throwing tantrums, and attempting to hit petitioner.
• Respondent was financially irresponsible, withdrawing a large sum of money saved by petitioner for childbirth to support his own parents and relatives instead.
• Respondent was emotionally and verbally abusive, neglected petitioner during her pregnancy, preferred spending time with friends, and eventually told petitioner he no longer loved her.
• In August 2007, approximately one year into the marriage, respondent abandoned petitioner and their child and was never heard from again.
• Petitioner filed for nullity of marriage on July 19, 2010; respondent, despite receiving summons, did not file an answer or participate in the trial.
• Petitioner presented her own testimony, the testimony of a neighbor who knew of respondent's irresponsibility and womanizing, and the testimony of clinical psychologist Dr. Maricris Reyes Marucut.
• Dr. Marucut, based on interviews with petitioner, her sister, and common friends, concluded in a psychological report that respondent suffered from Passive-Aggressive Personality Disorder with narcissistic traits, which was grave, permanent, and incurable.

• The respondent is psychologically incapacitated to perform his essential marital obligations, as demonstrated by his acts of abandonment, failure to provide financial and emotional support, and verbal abuse.
• The totality of the evidence presented, including her uncontroverted testimony and the expert findings of the clinical psychologist, sufficiently proves the gravity, juridical antecedence, and incurability of the respondent's condition.
• The Court of Appeals erred in reversing the RTC's decision, as it improperly disregarded the evidence establishing respondent's psychological incapacity under Article 36 of the Family Code.

• The respondent did not file an answer or participate in the proceedings; the arguments against the petition were raised by the Republic of the Philippines, through the Office of the Solicitor General (OSG), as the oppositor.
• The OSG argued that the evidence presented was insufficient to prove psychological incapacity, as respondent's actions of leaving the family, failing to provide support, and falling out of love do not automatically rise to the level of a psychological disorder.
• The OSG contended that the psychological report prepared by Dr. Marucut was unreliable and failed to conclusively establish a psychological illness because the respondent himself was never interviewed.

• Procedural Issues:
  • Whether a psychological report, prepared without a personal interview of the respondent, is sufficient to prove psychological incapacity.
• Substantive Issues:
  • Whether the respondent's demonstrated acts of abandonment, financial irresponsibility, and emotional neglect constitute psychological incapacity under Article 36 of the Family Code, as interpreted by the prevailing jurisprudence.

• Procedural:
  • Yes, the psychological report can be given credence. The Court held that a psychological diagnosis is not indispensable to a petition for nullity under Article 36. Citing Tan-Andal, the Court affirmed that it is accepted practice in psychiatry to base a person's psychiatric history on collateral information, especially when the subject is unavailable or refuses to cooperate. The credibility of an expert witness lies in their special knowledge and methodology, not in having personal knowledge of the case's facts.
• Substantive:
  • Yes, the respondent is psychologically incapacitated. The Court found that petitioner proved her case by clear and convincing evidence. Applying the refined requisites from Tan-Andal, the respondent's actions demonstrated an undeniable and persistent pattern of failure to be a present, loving, and supportive spouse. His behavior was not mere refusal or neglect but was rooted in a genuine anomaly in his psychological makeup, rendering him truly incapable of performing his essential marital obligations. The Court found that the requisites of gravity, juridical antecedence, and incurability (in a legal sense) were all satisfied.

• Psychological Incapacity (as refined in Tan-Andal v. Andal) — This doctrine defines psychological incapacity not as a medical illness but as a legal concept referring to a party's clear, grave, and enduring inability to comprehend and comply with essential marital obligations due to psychic causes. In this case, the Court applied this refined standard to find that respondent's pattern of abandonment, irresponsibility, and abuse, rooted in his personality structure, constituted psychological incapacity without requiring a formal medical diagnosis.
• Clear and Convincing Evidence — This is the standard of proof required to establish psychological incapacity. The Court determined that the petitioner's uncontroverted testimony, corroborated by witness statements and the psychological evaluation, met this standard by presenting a coherent and convincing account of the respondent's inability to fulfill his marital duties.
• Admissibility of Expert Testimony based on Collateral Information — The Court reiterated the principle that the credibility of an expert witness stems from their specialized knowledge, skill, and methodology, not from personal knowledge of the case's facts. This was applied to uphold the validity of Dr. Marucut's psychological report, which was based on interviews with the petitioner and other informants, as this is an accepted practice in psychiatry when the subject is unavailable or uncooperative.

• "x x x Psychological incapacity is neither a mental incapacity nor a personality disorder that must be proven through expert opinion. There must be proof, however, of the durable or enduring aspects of a person's personality, called 'personality structure,' which manifests itself through clear acts of dysfunctionality that undermines the family. The spouse's personality structure must make it impossible for him or her to understand and, more important, to comply with his or her essential marital obligations."
• "[T]here will be no need to label a person as having a mental disorder just to obtain a decree of nullity. A psychologically incapacitated person need not be shamed and pathologized for what could have been a simple mistake in one's choice of intimate partner, a mistake too easy to make as when one sees through rose-colored glasses."

• Tan-Andal v. Andal — This case was cited as the controlling precedent that established a fundamental paradigm shift in the interpretation of psychological incapacity. The Court used it to clarify that the condition is a legal, not medical, concept and to refine the definitions of its three requisites: gravity, juridical antecedence, and incurability.
• Republic v. Molina — This case was cited in a footnote from the Tan-Andal opinion in the context of defining gravity. The ruling in Cayabyab-Navarrosa represents a continued application of the more liberal approach established in Tan-Andal, which moved away from the rigid requirements of the Molina doctrine.

• Article 36, Family Code of the Philippines — This is the central statutory provision that allows for a marriage to be declared void ab initio if one of the parties was, at the time of the celebration, psychologically incapacitated to comply with the essential marital obligations, even if such incapacity becomes manifest only after the solemnization.