REPUBLIC OF THE PHILIPPINES v. DANILO A.

PANGASINAN
G.R. No. 214077, 10 August 2016
Velasco, Jr., J.

DOCTRINE: Mere showing of irreconcilable differences and conflicting personalities does

not constitute psychological incapacity nor does failure of the parties to meet their
responsibilities and duties as married persons.

FACTS: After thirty years of marriage, Respondent Danilo Pangasinan (Danilo) filed before
the Regional Trial Court (RTC) a petition for the declaration of nullity of marriage to
Josephine Pangasinan (Josephine) on the ground of the latter’s psychological incapacity
under Article 36 of the Family Code. According to Danilo, Josephine exhibited negative
traits at the onset of their relationship, such as being competitive, domineering, headstrong,
and exaggerated sense of self-importance and sense of entitlement. Also, Danilo and
Josephine have disagreements over financial and trivial matters, which usually end up in
fights. This claim was supported by the Psychological Evaluation Report of Dr. Natividad
Dayan (Dr. Dayan) who concluded that Josephine and Danilo were psychologically
incapacitated to fulfill their essential marital obligations.

The RTC declared the marriage of Danilo and Josephine void from the beginning, noting that
the totality of evidence presented show that they failed to establish a functional family. The
RTC also gave credence to the evaluation report of Dr. Dayan. The Court of Appeals (CA)
affirmed the RTC’s decision upon review. Hence, the petition.

ISSUE: Whether or not the totality of evidence presented warrants the declaration of nullity
of marriage of Danilo and Josephine based on their psychological incapacity under Art. 36 of
the Family Code.

HELD: NO. The Supreme Court held that Danilo failed to establish the totality of evidence
to establish psychological incapacity of the parties. As declared by the Court in Santos v. CA,
psychological incapacity must be characterized by gravity, juridical antecedence and
incurability. Further, a person’s psychological incapacity to comply with his/her marital
obligations must be rooted on a medically or clinically identifiable illness that is incurable
and shown to have existed at the time of the marriage, although manifestation of which may
only be evident after marriage.

In the present case, the Court found that there is no reliable and independent evidence
establishing Josephine’s psychological condition and its association in her early life. Aside
from what Danilo relayed to Dr. Dayan, no other evidence supports his claims. Further, Dr.
Dayan’s testimony is inadequate to establish the correlation between Josephine’s personality
and her inability to comply with her marital obligations to Danilo. At most, it only
establishes that their personalities are different and that their frequent arguments in handling
finances and managing their business affairs are money-related. Thus, the Court held that
Mere showing of irreconcilable differences and conflicting personalities does not constitute
psychological incapacity nor does failure of the parties to meet their responsibilities and
duties as married persons.

RULING: The petition is GRANTED. The Decision of CA is SET ASIDE. Petition for
Nullity of Marriage is DENIED.