### Facts:
Rommel Espiritu filed a petition for the declaration of nullity of his marriage with Shirley Ann Boac-Espiritu on July 28, 2010, under Article 36 of the Family Code, claiming psychological incapacity on the part of the respondent. After meeting through a common friend in August 1998 and becoming lovers, they married on July 18, 2000, and had three children. Rommel alleged that Shirley exhibited signs of “psychological incapacity” such as refusal to have sex, constant nagging, jealousy, and irresponsibility towards their children, leading him to consult a clinical psychologist who diagnosed Shirley with Histrionic Personality Disorder and Paranoid Personality Disorder. Despite notices and summons, Shirley failed to respond to the petition. The Regional Trial Court (RTC) denied the petition, finding the evidence insufficient. Rommel’s motion for a new trial was also denied. The Court of Appeals affirmed the RTC’s decision, questioning the reliability of Dr. Tudla’s findings which were based solely on information from Rommel and his witnesses without direct examination of Shirley.
### Issues:
1. Whether the alleged psychological incapacity of Shirley Ann Boac-Espiritu as diagnosed based on the testimonies of Rommel Espiritu and his witnesses without direct examination meets the legal standard for the declaration of nullity of marriage under Article 36 of the Family Code.
2. The relevance and necessity of expert opinion in establishing psychological incapacity.
3. The application of the clear and convincing evidence standard in cases of psychological incapacity for the annulment of marriage.
### Court’s Decision:
The Supreme Court denied the petition, affirming the decisions of the lower courts that the evidence presented was insufficient to prove Shirley’s psychological incapacity as per the legal requirements. The Court mentioned that mere difficulty, nagging, jealously, and mistrust do not equate to psychological incapacity. Furthermore, the Court emphasized that the diagnosis of a psychologist, although not outright dismissed, lacks competencies if it was solely based on the account of the petitioning party without direct examination of the respondent. The Court also reiterated the view that psychological incapacity involves clear acts of dysfunctionality due to psychic causes that are permanent or incurable in nature, which in this case, was not substantially proven.
### Doctrine:
This case reiterates that psychological incapacity under Article 36 of the Family Code requires clear and convincing evidence of an incapacity that is juridical, antecedent, grave, and incurable. Furthermore, expert opinion, while not mandatory, must be reliable and based on substantial foundation if presented as evidence.
### Class Notes:
– Psychological incapacity as a ground for the nullity of marriage must display a complete inability to discharge the essential marital obligations due to causes psychologic in nature, permanent or incurable.
– It is required that the condition exists at the time of the marriage and has persisted thereafter.
– Direct examination of the respondent by a psychologist or psychiatrist, while valuable, is not a stringent requirement as long as the totality of evidence presented sufficiently proves incapacity.
– The burden of proof in annulment cases on the ground of psychological incapacity is on the petitioner, who must present clear and convincing evidence.
### Historical Background:
This case underlines the stringent standards set by the Philippine legal system in adjudicating annulment cases based on psychological incapacity. It highlights the evolutionary interpretation by the Supreme Court of the requirements under Article 36 of the Family Code since its enactment, reinforcing the principle that marriage is an inviolable social institution that demands rigorous scrutiny before it can be nullified based on psychological incapacity.
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