**Facts:**
Carolyn T. Mutya-Sumilhig (Carolyn) and Joselito T. Sumilhig (Joselito) began working together in February 1984. Following a romantic relationship, they married after Carolyn became pregnant. During their relationship and marriage, Joselito exhibited gambling and drinking habits, was often jobless, and would physically and verbally abuse Carolyn and their children. In September 1990, unable to endure his abuse, Carolyn left. Attempts to reconcile failed, and Joselito eventually lived with another woman.
On October 18, 2010, Carolyn filed for annulment of the marriage under Article 36 of the Family Code, claiming psychological incapacity on Joselito’s part. She submitted various affidavits and medical reports to support her claims. Joselito did not file an answer. Dr. Soriano diagnosed Joselito with Antisocial-Dependent Personality Disorder, compounded by alcohol dependence and pathological gambling.
The Regional Trial Court (RTC) and the Court of Appeals (CA) both found insufficient evidence to prove Joselito’s incapacity. Carolyn disagreed with the lower court’s decision and brought the case before the Supreme Court.
**Issues:**
1. Whether Joselito T. Sumilhig’s actions constitute psychological incapacity under Article 36 of the Family Code.
2. Whether the totality of evidence supports a finding of psychological incapacity.
**Court’s Decision:**
The Supreme Court found that the totality of evidence clearly and convincingly established Joselito’s psychological incapacity at the time of the marriage. This incapacity was characterized by a serious psychological illness that effectively rendered him unable to assume the essential marital obligations. It was determined that Joselito’s condition was juridical antecedent, meaning it existed prior to the marriage; incurable, not in a clinical sense but as a deep-seated and enduring difficulty; and grave, demonstrating a complete inability to be a present and responsible spouse or parent.
**Doctrine:**
The Supreme Court established that psychological incapacity under Article 36 of the Family Code does not necessarily require the medically incurable nature of the incapacity but requires an incapability to carry out essential marriage obligations due to an enduring personal condition existing at the commencement of the marriage.
**Class Notes:**
– Juridical Antecedence: Psychological incapacity must exist at the time of the marriage’s celebration.
– Incapacity must be incurable, not necessarily in the medical sense, but rather indicative of a persisting inability to fulfill marital responsibilities.
– Gravity: The incapacity must be severe, excluding minor character peculiarities or mood changes, and demonstrate an inability to assume basic marital obligations.
– The totality of evidence principle indicates that psychological incapacity can be established through various forms of evidence, not only the personal interview or examination of the respondent by the psychologist or psychiatrist.
– Psychological incapacity is a personal condition preventing a spouse from complying with essential matrimonial duties, not merely a refusal or difficulty to perform them.
**Historical Background:**
The concept of psychological incapacity in Philippine jurisprudence is a relatively modern development shaped by evolving understandings of mental health and its impact on relational dynamics. Since its inclusion in the Family Code, courts have been interpreting Article 36 to adapt to complex personal circumstances in marriage annulment cases, balancing the intentions of marital permanence with the realities of profound personal dysfunction. This case reinforces the principle that psychological incapacity is not simply bad behavior or a refusal to assume responsibilities, but a deep-rooted condition influencing a person’s ability to engage in a mutual and fulfilling marital relationship.
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