Siayngco vs. Siayngco, G.R. No. 158896, October 27, 2004 - SHORTER

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86. Siayngco vs. Siayngco, G.R. No.

158896, October RULING: NO


27, 2004
It was in Santos v. Court of Appeals42 where we declared
FACTS:
that "psychological incapacity" under Article 36 of the
Family Code is not meant to comprehend all possible
Petitioner Juanita Carating-Siayngco ("Petitioner cases of psychoses.
Juanita") and respondent Manuel were married a
It should refer, rather, to no less than a mental (not
after twenty-four (24) years of married life together, physical) incapacity that causes a party to be truly
respondent Manuel filed for the declaration of its nullity incognitive of the basic marital covenants that
on the ground of psychological incapacity of petitioner concomitantly must be assumed and discharged by
Juanita. the parties to the marriage.

He alleged that Psychological incapacity must be characterized by

1. all throughout their marriage, his wife exhibited (a) gravity,


an over domineering and selfish attitude
towards him which was exacerbated by her (b) juridical antecedence, and
extremely volatile and bellicose nature;
(c) incurability.43 In Republic v. Court of Appeals44 we
2. that she incessantly complained about almost
expounded:
everything and anyone connected with him

3. that she showed no respect or regard at all for from the totality of the evidence adduced by both
the prestige and high position of his office as parties, we have been allowed a window into the
judge of the Municipal Trial Court; Siayngcos’s life and have perceived therefrom a simple
case of a married couple drifting apart, becoming
4. that her psychological incapacity arose before strangers to each other, with the husband consequently
marriage, rooted in her deep-seated resentment falling out of love and wanting a way out.
and vindictiveness for what she perceived as
lack of love and appreciation from her own An unsatisfactory marriage, however, is not a null and
parents since childhood and that such incapacity void marriage.
is permanent and incurable
Mere showing of "irreconcilable differences" and
petitioner Juanita alleged that respondent Manuel "conflicting personalities" in no wise constitutes
invented malicious stories against her so that he could psychological incapacity.59
be free to marry his paramour;

2 psychiatrists were admitted, and both of whom


declared parties that parties are not psychologically
incapacitated.

court denied respondent Manuel’s petition for


declaration of nullity of his marriage to petitioner Juanita
because the asserted psychological incapacity of the
defendant is not preponderantly supported in evidence

ISSUE: WON, the court erred in denying the petition?

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