David Dedel vs Court of Appeals & Sharon Corpuz-Dedel

November 20, 2010

In 1966, David and Sharon married each other. Theyve had four children since then. David then found out that
Sharon is irresponsible as a wife and as a mother because during the marriage Sharon had extra-marital affairs with
various other guys particularly with one Mustafa Ibrahim, a Jordanian, with whom she had 2 children. She even
married Ibrahim. David averred that Sharon is psychologically incapacitated and David submitted the findings of Dr.
Dayan which shows that Sharon is indeed psychologically incapacitated. Dr. Dayan declared that Sharon was
suffering from Anti-Social Personality Disorder exhibited by her blatant display of infidelity; that she committed several
indiscretions and had no capacity for remorse, even bringing with her the two children of Mustafa Ibrahim to live with
petitioner. Such immaturity and irresponsibility in handling the marriage like her repeated acts of infidelity and
abandonment of her family are indications of Anti-Social Personality Disorder amounting to psychological incapacity
to perform the essential obligations of marriage.

ISSUE: Whether or not PI has been proven.

HELD: PI is not proven in court in this case. The evidence is not sufficient. PI is intended to the most serious cases of
personality disorders which make one be incapable of performing the essential marital obligations. Sharons sexual
infidelity does not constitute PI nor does it constitute the other forms of psychoses which if existing at the inception of
marriage, like the state of a party being of unsound mind or concealment of drug addiction, habitual alcoholism,
homosexuality or lesbianism, merely renders the marriage contract voidable pursuant to Article 46, Family Code. If
drug addiction, habitual alcoholism, lesbianism or homosexuality should occur only during the marriage, they become
mere grounds for legal separation under Article 55 of the Family Code. These provisions, however, do not
necessarily preclude the possibility of these various circumstances being themselves, depending on the degree and
severity of the disorder, indicia of psychological incapacity. Sexual infidelity is not one of those contemplated in law.
Until further statutory or jurisprudential parameters are set or established, SI cannot be appreciated in favor of the
dissolution of marriage.