ESPIRITU vs.

BOAC-ESPIRITU
G.R. No. 247583, OCTOBER 6, 2021
LAZARO-JAVIER, J.

Facts: Rommel Espiritu filed a petition for the declaration of nullity of his marriage with
Shirley Ann Boac-Espiritu. Petitioner Rommel alleged that respondent Shirley Ann
exhibited psychological incapacity, which hindered her from fulfilling her marital
obligations. Petitioner claimed that respondent refused to have sex with him, demanded
to be alone, is a constant nagger, always picked fights with him, accused him of infidelity,
and neglected their children. Petitioner presented the testimony of a clinical
psychologist, Dr. Pacita Tudla. Based on interviews with petitioner, their driver, and their
neighbor, Dr. Tudla diagnosed respondent with Histrionic Personality Disorder and
Paranoid Personality Disorder. The couple separated in 2008. Respondent did not
respond to the petition.

Issue: Whether or not petitioner has proven respondent's psychological incapacity to

justify the nullity of their marriage.

Ruling: The SC ruled in the negative and affirmed the validity of their marriage. The SC
held that petitioner failed to provide clear and convincing evidence of Respondent's
psychological incapacity. First, petitioner's evidence only offered general statements of
respondent's alleged manifestations of psychological incapacity, without providing a
complete picture of her actions. There may have been factors contributing to
respondent's behavior, such as petitioner's alleged infidelity. Second, the SC
emphasized that psychological incapacity is not a personality disorder or a medical
illness that requires expert opinion. The findings of Dr. Tudla failed to specifically show
how respondent’s personality traits are indeed clear acts of dysfunctionality, making it
impossible for her to understand and comply with her essential marital obligations. Third,
there is no clear and convincing evidence of juridical antecedence, gravity, and
incurability of respondent's personality structure. Even if the couple had long been
separated, the SC weighed the consequences of petitioner’s claims. The SC ruled that it
is not fair to call respondent psychologically incapacitated and deficient in her role as a
spouse and mother when probably, as the more or at least equally likely inference
shows, she may also have been a victim of this loveless and stressful marriage.
Depending on who the survivor is, and who holds economic power, the power imbalance
that could arise from the nullification of the marriage could weigh heavily and adversely
upon respondent. She was the one left with the children's upbringing, and more likely
than not, had to sacrifice at least a portion of her own independent career for so many
years for her children and the family.