Soto vs. Reyes-Soto

Psychological incapacity under Article 36 of the Family Code is a legal, not medical, concept that may be established through ordinary and expert evidence of enduring personality structures rendering genuine marital life impossible, and the factual findings of the trial court affirmed by the Court of Appeals are binding and not reviewable in a Rule 45 petition.

Juanito B. Soto and Cassandra Reyes-Soto met as college students at the University of the Philippines in 1979 and later became coworkers at the Bank of the Philippine Islands. They married in September 1983, prompted by Reyes-Soto's pregnancy. The marriage produced one child, Carmela. The case arises under Article 36 of the Family Code, which declares void a marriage contracted by a party psychologically incapacitated to comply with essential marital obligations. The doctrinal framework governing Article 36 was significantly refined during the pendency of this case by Tan-Andal vs. Andal (2021), which abandoned the rigid Molina guidelines and reconfigured psychological incapacity as a legal concept not requiring clinical diagnosis or expert opinion.

Soto and Reyes-Soto met and became friends in 1979 while they were college students at the University of the Philippines, Quezon City. After graduation, they remained in contact and grew closer while attending a six-week information technology training program at International Business Machines Corporation. Both were eventually hired by the Bank of the Philippine Islands, where, as officemates, they spent at least ten hours together each day. Soto also frequently visited Reyes-Soto at her house and they occasionally attended social gatherings together. In May 1981, they officially considered themselves a couple.

In July 1983, Reyes-Soto transferred to another bank while Soto remained at BPI and pursued further studies. Around this time, Reyes-Soto learned she was pregnant. Because of the pregnancy, the couple decided to marry in September 1983 and proceeded with wedding preparations. During this period, Reyes-Soto noticed that Soto showed little concern for her pregnancy and did not accompany her to prenatal checkups, prompting her to ask friends to go with her instead. She began to harbor reservations about their relationship, sensing a lack of affection from Soto, who was emotionally never expressive. She wondered whether they were marrying out of love or merely because of the pregnancy, but she did not express her concerns and ultimately decided to proceed with the wedding.

After the wedding, the couple lived with Reyes-Soto's parents in Antipolo, Rizal. Reyes-Soto gave birth to their only child, Carmela. The birth introduced new challenges, particularly in their differing approaches to parenting. Soto would tell Reyes-Soto that she was spoiling Carmela whenever she devoted time and attention to the child, while Reyes-Soto observed that Soto rarely engaged in meaningful bonding activities with their daughter and did not even spend time playing with her. They seldom went out together as a family. Sometime later, the family moved to Pasig City to live with Soto's parents. Reyes-Soto was uncomfortable with the arrangement but accepted it as temporary and necessary for saving money. Over time, she perceived that Soto made no decisive effort to assert their independence and continued to defer to his mother, on whom he appeared emotionally dependent. She did not raise her discomfort or growing frustration with him.

Tensions intensified when Soto's mother disciplined Carmela by spanking her. Reyes-Soto brought this to Soto's attention, and he promised to speak with his mother. However, Soto's mother reacted coldly toward Reyes-Soto and Soto did not intervene. Reyes-Soto came to believe that Soto's mother exerted considerable influence over him and that his mother's presence intruded permanently into their married life. Soto acknowledged the disagreement over his mother's discipline style and told Reyes-Soto they would move out after he completed his master's degree. He also admitted that his mother frequently gave them "unending advice," which Reyes-Soto perceived as meddling. Reyes-Soto further described their life together as monotonous and routine — they would go to work, return home to sleep, and repeat the cycle. They rarely engaged in family activities, did not share a warm or affectionate relationship, and had not engaged in intimate relations since 1986. Reyes-Soto attempted to persuade Soto to move out of his parents' home, suggesting they sell a lot in Cavite that Soto's parents intended to give them. When Soto relayed this proposal to his mother, she rejected it, and Soto complied. Reyes-Soto felt deeply rejected by his continued deference. Despite these mounting issues, neither spouse made meaningful efforts to nurture or repair the relationship.

In 1987, Reyes-Soto told Soto that she was unhappy and wished to live separately. Soto did not engage her in meaningful discussion and responded with silence. In 1988, Soto decided to seek employment in the United States, and they agreed that Reyes-Soto and Carmela would join him once he secured stable work. Reyes-Soto initially agreed, but later informed Soto that she and Carmela would no longer migrate. In December 1989, Reyes-Soto and Carmela visited Soto in the United States and spent Christmas together, but Soto made no effort to reconcile. Their time together mirrored the routine life they had in the Philippines — no romantic moments, no bonding between Soto and Carmela. Whenever the spouses talked, Reyes-Soto would tell Soto that "maski kasama kita, hindi ako masaya." Upon returning to the Philippines, Reyes-Soto and Carmela moved out of Soto's parents' home and returned to Reyes-Soto's parents' residence. Soto made no genuine effort to persuade her to reconsider. It was the parties' parents who urged her to join Soto in the United States. Soto rarely visited Carmela; instead, Reyes-Soto brought Carmela to the United States every summer. From 1989 to 2005, Soto sent approximately USD 200 to USD 300 for Carmela's educational expenses while Reyes-Soto covered her other needs. Throughout these years, Soto did not maintain stable and consistent communication with either Reyes-Soto or their daughter.

In 1994, Soto filed for divorce in the United States, admitting he did so out of frustration and in the hope it would prompt Reyes-Soto to reconcile. She remained resolute and the divorce was granted. In 2007, Soto returned to the Philippines permanently and occasionally visited Reyes-Soto, later telling her that one of his reasons for returning was to attempt to rekindle their marriage. She refused, feeling that after all those years of separation there was no marriage left to revive, and did not allow him to live with her and Carmela. In his interview with Dr. Cecilia Villegas, the psychiatrist who testified in the case, Soto stated that he frequently visited Reyes-Soto but she was "snobbish" and unresponsive, "to the point of 'binabastos na ako,'" and he eventually stopped visiting. In 2013, Reyes-Soto filed a petition for declaration of nullity of their marriage under Article 36 of the Family Code.

The RTC granted the petition, relying on the testimonies of Reyes-Soto, her sister Celine Claire Maria Reyes, and Dr. Villegas. Dr. Villegas conducted personal interviews with both Soto and Reyes-Soto and reviewed psychological test results administered by another clinical psychologist. She diagnosed Reyes-Soto with Passive-Aggressive Personality Disorder and Soto with Inadequate Personality Disorder along masculine strivings to the degree of oedipal complex. She traced both disorders to the parties' formative years — Reyes-Soto's to a strict, disciplinarian mother and the emotional deprivation caused by an ailing sibling and an absent father, and Soto's to maternal over-protection that arrested his emotional development at an infantile level. She testified that both disorders were permanent and incurable. The RTC found these findings, together with the lay testimony, sufficient to declare the marriage void. The CA initially reversed, then upon reconsideration reinstated the RTC ruling. Soto then filed the present petition.

• Insufficiency of Evidence: Petitioner argued that there was no adequate evidence that either party had a psychological disorder characterized by juridical antecedence, gravity, and incurability, and that the respondent "merely fell out of love and grew dissatisfied with her marriage."
• Credibility of Expert Testimony: Petitioner asserted that Dr. Villegas's testimony and Psychiatric Report were not credible because her findings were based on hearsay, specifically the result of psychological tests conducted by a third person.
• Nature of the Issue: Petitioner insisted that he was raising a question of law, not fact, because he did not question the truth or falsity of the facts established but only challenged the CA's legal conclusions as to whether the parties' psychological conditions fall under Article 36.
• Property Partition: Petitioner argued that even assuming the marriage was void, the CA erred in not remanding the case to the RTC for proper inventory, liquidation, dissolution, and partition of their properties.

• Procedural Impropriety: Respondent argued that the petitioner raised questions of fact in his Petition, which are improper in a Rule 45 petition.
• Sufficiency of Evidence: Respondent maintained that the parties' respective psychological incapacity was duly established by the petitioner's own testimony, Celine's testimony, and Dr. Villegas's testimony, which were even corroborated by the petitioner himself.
• Credibility of Expert Testimony: Respondent countered that the RTC and CA correctly ruled Dr. Villegas's testimony credible, that even without the psychological test administered by another psychologist the findings would still hold true, and that the tests "merely confirmed and boosted" Dr. Villegas's psychiatric evaluation. She also noted Dr. Villegas's recognized expertise and her clear explanation of the processes and tests relied upon.

• Nature of the Issue: Whether the questions raised in the Petition are questions of fact, which are improper in a Rule 45 petition for review on certiorari.
• Psychological Incapacity: Whether the marriage between the petitioner and the respondent is void because of their psychological incapacity under Article 36 of the Family Code.
• Property Partition: Whether the CA erred in not remanding the case for liquidation and partition of the parties' co-owned properties as a prerequisite to the declaration of nullity.

• Nature of the Issue: Yes, the issues are questions of fact. The petitioner's contentions require reassessment of the credibility of witnesses, the probative value of expert testimony, and the sufficiency of evidence — exercises beyond the Court's authority under Rule 45, which is limited to questions of law.
• Psychological Incapacity: Yes, both parties are psychologically incapacitated under Article 36. The evidence — Dr. Villegas's expert testimony, lay testimony, and the parties' own admissions — established juridical antecedence, incurability, and gravity with clear and convincing evidence.
• Property Partition: No. The partition of co-owned properties is not a precondition to a declaration of nullity but is merely incidental to it. Under Article 147 of the Family Code and Diño vs. Diño, the parties may partition properties by agreement or judicial proceeding, and the court need not mandate partition in the nullity proceeding itself.

• Nature of the Issue: The distinction between questions of law and fact is well established: a question of law exists when the doubt concerns the correct application of law to a given set of facts without examining the probative value of evidence, while a question of fact exists when the issue calls for calibration of the whole evidence, including witness credibility and the probability of factual inferences. The petitioner does not dispute the existence of the testimonies but assails their sufficiency, credibility, and weight — insisting that Dr. Villegas's conclusions are unreliable and that the evidence fails to establish juridical antecedence, gravity, and incurability. These contentions require reexamination of evidence, assessment of admissibility and credibility, and factual conclusions — all quintessentially questions of fact. Rule 45 limits the Court's review to questions of law only. The factual findings of the RTC, affirmed by the CA after reconsideration, are binding, and none of the recognized exceptions obtain. On this ground alone, the petition should be dismissed.

• Psychological Incapacity: Applying the doctrinal framework refined in Tan-Andal vs. Andal and Georfo vs. Republic, psychological incapacity is a legal, not medical, concept consisting of clear acts of dysfunctionality showing a lack of understanding and compliance with essential marital obligations due to psychic causes. It must be characterized by juridical antecedence (existing at the time of celebration, even if manifesting only after), incurability (legally, not medically — so enduring and persistent with respect to a specific partner that the marriage is beyond repair), and gravity (arising from a genuinely psychic cause, not mere refusal, neglect, or difficulty). Expert opinion is not required but may be admitted as an aid; ordinary witnesses may testify on behaviors consistently observed. Dr. Villegas's testimony was credible: she personally interviewed both parties, clearly explained her methodology, and testified that the psychological tests administered by a third person were corroborative rather than determinative, her interview findings and test results having "jibed." Juridical antecedence was established through Dr. Villegas's tracing of both parties' incapacity to their formative years — Reyes-Soto's strict, disciplinarian mother, emotional rejection due to an ailing sibling, and prolonged father absence; Soto's maternal over-protection and arrested emotional development. Incurability was shown through the deeply engrained nature of both disorders and the decades-long pattern of emotional disengagement, absence of intimacy since the late 1980s, and consistent inability to re-establish an emotional bond. Gravity was demonstrated by the utter inability of both parties to give meaning and substance to the marriage — Reyes-Soto's passive-aggressive withdrawal and unexpressed resentment, and Soto's inability to provide emotional intimacy due to his conflated filial and marital attachments. The evidence revealed incompatible and mutually reinforcing personality structures that rendered genuine marital life impossible from the outset.

• Property Partition: The property relations of parties in a void marriage are governed by Article 147 or 148 of the Family Code. Under Diño vs. Diño, a court ruling on an Article 36 petition can nullify the marriage without requiring liquidation of properties in the same proceeding. Article 496 of the Civil Code provides that partition of co-owned properties may be made by agreement or judicial proceedings. The parties are free to choose whether to partition through agreement or judicial proceeding, and the Court need not preempt this choice by mandating partition in the nullity case.

• Psychological Incapacity as a Legal Concept (Tan-Andal Doctrine) — Psychological incapacity under Article 36 consists of clear acts of dysfunctionality showing a lack of understanding and compliance with essential marital obligations due to psychic causes. It is not a medical illness requiring clinical identification; expert opinion is not required. The incapacity must be caused by a durable aspect of one's personality structure formed before marriage. The second Molina guideline — requiring proof of a medically or clinically identified personality disorder through expert opinion — was categorically abandoned. Ordinary witnesses who were present in the life of the spouses before marriage may testify on consistently observed behaviors; the judge then decides whether these behaviors indicate true and serious incapacity.

• Three Requisites of Psychological Incapacity (Juridical Antecedence, Incurability, Gravity) — As refined in Tan-Andal and Georfo: (1) Juridical antecedence — the incapacity existed at the time of celebration, even if it manifested only after; it may be proven by testimonies describing the environment where the supposedly incapacitated spouse lived, and it is enough that the petitioner show the incapacity "in all reasonable likelihood" already existed at the time of celebration. (2) Incurability — viewed in the legal, not medical, sense; the condition must be so enduring and persistent with respect to a specific partner that the couple's personality structures are so incompatible that the only result is the inevitable and irreparable breakdown of the marriage; there must be an undeniable pattern of persisting failure to be a present, loving, faithful, respectful, and supportive spouse. (3) Gravity — the incapacity must be caused by a genuinely psychic cause; it must not be mere mild characterological peculiarities, mood changes, occasional emotional outbursts, or mere refusal, neglect, difficulty, or ill will.

• Types of Evidence for Psychological Incapacity (Estella Doctrine) — Lay persons may testify about dysfunctional acts that undermine the family. The types of evidence include: (i) the reputation of the incapacitated spouse; (ii) the character of the incapacitated spouse relevant to such incapacity; (iii) the everyday behavior, acts, or conduct of the incapacitated spouse; (iv) the offended spouse's own experience of neglect, abandonment, unrequited love, and infliction of mental distress. Relevant circumstances include instances of violence against women and children, zero probability of reconciliation, and failure to perform marital duties clearly demonstrative of utter insensitivity or inability to give meaning and significance to the marriage.

• Binding Factual Findings in Rule 45 — The factual findings of the RTC, affirmed by the CA, are binding upon the Supreme Court in a Rule 45 petition. The Court is not a trier of facts and generally does not review questions of fact. None of the recognized exceptions to this rule applied in this case.

• Property Partition Not a Prerequisite to Nullity (Diño Doctrine) — A court ruling on an Article 36 petition can nullify the marriage without requiring liquidation of properties in the same proceeding. The partition of co-owned properties is not a precondition but is merely incidental to, and a consequence of, the nullity of the marriage. Under Article 496 of the Civil Code, partition may be made by agreement or by judicial proceedings.

• "Psychological incapacity consists of clear acts of dysfunctionality that show a lack of understanding and concomitant compliance with one's essential marital obligations due to psychic causes. It is not a medical illness that has to be medically or clinically identified; hence, expert opinion is not required." — This passage, quoted from Tan-Andal, articulates the foundational reconfiguration of psychological incapacity as a legal concept, central to the Court's analysis.

• "Silent dysfunction, manifested in emotional distance, withdrawal, and resignation, can be no less corrosive to the marital bond than more visible forms of incapacity, and it is no less within the contemplation of Article 36 of the Family Code." — This passage extends Article 36 to marriages void not because of overt dysfunction but because of quiet, deeply rooted psychological limitations, directly addressing the facts of this case.

• "To compel individuals to remain bound in a union that, from the start, functioned as a psychological case rather than a shared life of freedom and meaning does not strengthen marriage. It only transforms marriage into a site of quiet misery, erodes its dignity, and risks deterring others from entering it at all." — This passage articulates the Court's normative view that Article 36 is protective of, rather than hostile to, the institution of marriage.

• "The partition of the co-owned properties is not a precondition, but is merely incidental to, and is a consequence of, the nullity of the marriage." — This statement establishes the rule that property liquidation need not be resolved within the nullity proceeding itself.

• Tan-Andal vs. Andal, 902 Phil. 558 (2021) — Controlling precedent. The Court relied on Tan-Andal as the foundational reconfiguration of psychological incapacity as a legal concept, abandoning the second Molina guideline requiring proof of a medically identified personality disorder through expert opinion. The Court applied its framework throughout the analysis of juridical antecedence, incurability, and gravity.

• Georfo vs. Republic, 937 Phil. 518 (2023) — Followed. The Court relied on Georfo for the clarified definitions of the three requisites — juridical antecedence (existing at the time of celebration, provable through testimonies of environment), incurability (legal, not medical; enduring and persistent with respect to a specific partner), and gravity (genuinely psychic cause, excluding mere refusal, neglect, or difficulty).

• Estella vs. Perez, 911 Phil. 570 (2021) — Followed. The Court applied Estella's enumeration of types of evidence that lay persons may adduce to prove psychological incapacity, including reputation, character, everyday behavior, and the offended spouse's own experience of neglect and emotional distress.

• Halog vs. Halog, 912 Phil. 662 (2021) — Followed. The Court cited Halog for the proposition that while courts are not bound by expert conclusions, expert testimony is persuasive when given by a witness of special knowledge, grounded on sound methodology, and not based on hearsay. Also cited for the principle that there is no rule requiring an expert to personally interview both spouses for testimony to be admissible.

• Diño vs. Diño, 655 Phil. 175 (2011) — Followed. The Court applied Diño for the requisites of Article 147 and the holding that a court may nullify a marriage without requiring liquidation of properties in the same proceeding.

• Roxaco-Asia Hospitality Corp. vs. Gulf Canary Construction and Development, Inc., G.R. Nos. 246250-51, September 25, 2025 — Followed. Cited for the distinction between questions of law and questions of fact, which the Court applied to determine that the petitioner's contentions were questions of fact improper in a Rule 45 petition.

• Republic vs. Vega — Followed. Cited for the principle that when a petitioner asks for review based on the evidence presented without delving into their probative value but simply on their sufficiency to support legal conclusions, a question of law is raised — a principle the Court distinguished, finding that the petitioner's arguments in fact required reweighing evidence.

• Article 36, Family Code — Declares void a marriage contracted by a party who, at the time of celebration, was psychologically incapacitated to comply with essential marital obligations, even if such incapacity becomes manifest only after solemnization. The Court applied this provision as the central legal basis for declaring the marriage null, interpreting "psychological incapacity" through the Tan-Andal framework as a legal concept requiring proof of juridical antecedence, incurability, and gravity.

• Article 147, Family Code — Governs property relations in a void marriage where both parties are capacitated to marry, providing that wages and salaries are owned in equal shares and property acquired through work or industry is governed by co-ownership rules. The Court applied this provision to hold that the parties' properties are governed by co-ownership and that partition is not a prerequisite to nullity.

• Article 496, Civil Code — Provides that partition of co-owned properties may be made by agreement between the parties or by judicial proceedings. The Court cited this provision to support the holding that the parties are free to choose how to partition their co-owned properties, and that the court need not mandate partition in the nullity proceeding.

• Rule 45, Section 1, Rules of Court — Allows the Supreme Court to exercise discretionary power of review over questions of law only. The Court applied this rule to hold that the petitioner's contentions, being questions of fact, were improper in a Rule 45 petition.

Gesmundo, C.J. (Chairperson), Hernando, Zalameda, and Marquez, JJ., concurred. No separate concurring opinions were noted.