Tan Andal V Andal

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Quintero, Lorein R

DOCTRINE:
Psychological incapacity is neither a mental incapacity nor a personal disorder that must
be proven through expert opinion.

FACTS:
Rosanna filed for a petition for declaration of nullity of marriage on the ground of Mario's
psychological incapacity to comply with his essential marital obligations to her. Mario
was diagnosed with narcissistic antisocial personality disorder and substance abuse
disorder with psychotic features.
The RTC voided the marriage. The CA reversed RTC's ruling on the ground that the
psychiatric evaluation of Mario is "unscientific and unreliable" since he was not
interviewed.

ISSUE: WON the marriage is void due to psychological incapacity?

RULING:
YES. The Court finds Mario psychologically incapacitated to comply with his essential
marital obligations. Hence, the drug addiction is a ground for legal separation and will
not prevent the court from voiding the marriage, this should be enough to render the
marriage void under under Article 36 of the Family Code.

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