a.

Doctrine: Marriages; Declaration of Nullity of Marriage; Psychological

Incapacity; To warrant a declaration of nullity on the basis of Article 36,
the incapacity “must be grave or serious such that the party would be
incapable of carrying out the ordinary duties required in marriage; it
must be rooted in the history of the party antedating the marriage
although the overt manifestations maya emerge only after the
marriage; and it must be incurable or even if it were otherwise, the cure
would be beyond the means of the party involved.”
b. Case Title: Anacleto Alden Maneses vs. Jung Soon Linda Lee-
Meneses, G.R. No. 200182, (J. Caguioa) (March 13, 2019)
c. Facts:
1. On August 9, 1981, Anacleto and Linda were married. On June 3,
1983, Linda Monique L. Meneses, their only child, was born.
2. Linda wanted a luxurious life and she only appreciated her husband
when he bought her expensive gifts and took her out to fancy
expensive restaurants.
3. After ten years of living in Houston, Texas, USA, they decided to
relocate their business to Korea. When their business failed, they
decided to return to the Philippines.
4. During their marriage, they always fought about not having enough
money. The constant fighting and nagging caused Anacleto
humiliation; he lost self-esteem and suffered an erectile disorder.
5. In May 2005, after living together for almost 21 years, Linda left
Anacleto to live in Korea. Later on, she lived in the USA with their
daughter. She informed him that she would come back only if he
could give her a better life financially.
 6. On September 8, 2006, Anacleto filed a Petition for Declaration of
Nullity of before the RTC.
7. Anacleto presented the testimony of Dr. Arnulfo V. Lopez (Dr.
Lopez), a clinical psychiatrist.
8. On October 20, 2009, the RTC issued a Decision denying the
petition. RTC held that the totality of the evidence presented does
not show psychological incapacity on the part of Linda.
9. Anacleto filed a motion for reconsideration, which the RTC denied
for lack of merit in its Resolution dated July 6, 2010. Aggrieved,
Anacleto filed an appeal to the CA which was also denied. Anacleto
filed a motion for reconsideration, which was also denied by the CA
in the Assailed Resolution.
d. Issue/s: Whether the lower courts erred in dismissing Anacleto's
petition for declaration of nullity on the ground of insufficient evidence.
e. Held: xxx The Court has ruled that psychological incapacity under
Article 36 must be characterized by gravity, juridical antecedence, and
incurability. While the Court recognizes that there may very well be
grounds to nullify the marriage of Anacleto and Linda, the existence of
these grounds has not been sufficiently shown by the evidence
presented in this case.

WHEREFORE, the Petition is hereby DENIED. The Decision dated

July 19, 2011 and Resolution dated January 12, 2012 of the Court of
Appeals in CA-G.R. CV No. 95614 are AFFIRMED.

SO ORDERED.