Primary Holding
The Supreme Court held that the petitioner failed to prove that the respondent was psychologically incapacitated at the time of the marriage, as required by Article 36 of the Family Code. The Court emphasized that psychological incapacity must be grave, rooted in the party's history, and incurable, and must exist at the time of the marriage.
Background
Leouel Santos and Julia Rosario Bedia-Santos married in 1986. After the birth of their child, marital issues arose, primarily due to interference from Julia's parents. Julia left for the U.S. in 1988 and failed to return or maintain communication with Leouel. Leouel filed for nullity of marriage under Article 36, claiming Julia's behavior demonstrated psychological incapacity. The trial court and Court of Appeals dismissed the petition, leading to this Supreme Court review.
History
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1986: Leouel and Julia married.
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1988: Julia left for the U.S.
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1991: Leouel filed for nullity of marriage in the Regional Trial Court of Negros Oriental.
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1991: Trial court dismissed the petition.
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1992: Court of Appeals affirmed the trial court's decision.
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1995: Supreme Court denied the petition.
Facts
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1.
Leouel and Julia married in 1986 and had a child in 1987.
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2.
Marital issues arose due to interference from Julia's parents.
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3.
Julia left for the U.S. in 1988 and failed to return or communicate with Leouel.
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4.
Leouel filed for nullity of marriage under Article 36, claiming Julia's behavior showed psychological incapacity.
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5.
The trial court and Court of Appeals dismissed the petition.
Arguments of the Petitioners
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1.
Julia's failure to return home or communicate for over five years demonstrated psychological incapacity.
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2.
Julia's actions showed a lack of commitment to the marriage.
Arguments of the Respondents
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1.
Julia's failure to return home or communicate for over five years demonstrated psychological incapacity.
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2.
Julia's actions showed a lack of commitment to the marriage.
Issues
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1.
Whether Julia's behavior constituted psychological incapacity under Article 36 of the Family Code.
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2.
Whether the marriage should be declared null and void based on psychological incapacity.
Ruling
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1.
The Supreme Court denied the petition, ruling that Leouel failed to prove Julia was psychologically incapacitated at the time of the marriage.
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2.
The Court emphasized that psychological incapacity must be grave, rooted in the party's history, and incurable, and must exist at the time of the marriage.
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3.
The Court noted that Article 36 was not intended to be a ground for divorce but rather a means to address serious psychological disorders that prevent a party from fulfilling marital obligations.
Doctrines
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1.
Article 36 of the Family Code: Psychological incapacity must be grave, rooted in the party's history, and incurable, and must exist at the time of the marriage.
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2.
The Court emphasized that Article 36 should not be used as a substitute for divorce.
Key Excerpts
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1.
Article 36 of the Family Code: Psychological incapacity must be grave, rooted in the party's history, and incurable, and must exist at the time of the marriage.
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2.
The Court emphasized that Article 36 should not be used as a substitute for divorce.
Precedents Cited
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1.
Salita v. Hon. Magtolis (G.R. No. 106429, 13 June 1994): Cited for the interpretation of psychological incapacity under Article 36.
Statutory and Constitutional Provisions
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1.
Article 36 of the Family Code: Psychological incapacity as a ground for nullity of marriage.
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2.
Article 1 of the Family Code: Marriage as a special contract of permanent union.