G.R. No. 203992. August 22, 2022 (Case Brief / Digest)

### Title:

**Antonio S. Quiogue, Jr. vs. Maria Bel B. Quiogue and The Republic of the Philippines: A Psychological Incapacity in Marriage Case**

### Facts:

In 1980, Antonio S. Quiogue, Jr., and Maria Bel B. Quiogue (Maribel) were wed. Their union produced four children but eventually deteriorated, leading to their separation in fact by 1998. Antonio filed a Petition for Declaration of Nullity of Marriage on the ground of psychological incapacity under Article 36 of the Family Code, before the RTC, claiming both were incapable of fulfilling basic marital obligations. Maribel countered, attributing the separation to Antonio’s infidelity and abuse. The RTC ruled in favor of nullifying the marriage, citing psychological incapacity. However, the CA reversed this decision, finding the evidence insufficient for such a declaration. Antonio then appealed to the Supreme Court.

### Issues:

1. Whether Antonio’s infidelity and Maribel’s actions constitute psychological incapacity.
2. Whether the psychological incapacity, if any, satisfies the criteria of gravity, antecedence, and incurability.
3. The admissibility and weight of psychiatric evaluations in proving psychological incapacity.

### Court’s Decision:

The Supreme Court granted the petition, reversing the CA’s decision and declaring the marriage void due to Antonio’s psychological incapacity. The Court established that Antonio’s chronic infidelity, deeply rooted in his personality and history, satisfied the criteria for psychological incapacity: gravity, antecedence, and incurability.

1. **Infidelity as a manifestation of psychological incapacity**: Antonio’s repeated marital indiscretions were not merely instances of neglect but stemmed from a narcissistic and histrionic personality disorder present before the marriage.

2. **Criteria for psychological incapacity**: The Court found Antonio’s incapacity grave, antecedent to the marriage, and incurable, establishing a clear pattern unable to comply with the essential marital obligations of fidelity, mutual love, and respect.

3. **Psychiatric evaluation**: Dr. Garcia’s evaluation, corroborated by testimonies and documentary evidence, was instrumental in establishing Antonio’s psychological incapacity’s nature and extent.

### Doctrine:

1. **Psychological Incapacity under Article 36**: The Court reiterated that psychological incapacity involves incapacity both to understand and to fulfill the essential obligations of marriage, not mere refusal or neglect.

2. **Tan-Andal Framework**: Aligning with recent jurisprudence, the Court emphasized that psychological incapacity should not solely be viewed from a medical perspective but should consider the totality of evidence showing the party’s inability to perform marital obligations.

### Class Notes:

– **Psychological Incapacity Elements**: For a successful petition under Article 36, the incapacity must be grave, antecedent to the marriage, and incurable.
– **Evidence**: The totality of evidence, including expert psychiatric evaluations and the personal histories of the parties, is crucial in establishing psychological incapacity.
– **Legal Implications of Infidelity**: Chronic infidelity, when rooted in a psychological condition existing before the marriage, can constitute psychological incapacity.
– **Doctrine of Incurability in Legal Sense**: Incurability, as used in cases of psychological incapacity, does not require medical incurability but should be seen as an enduring condition affecting marital obligations.

### Historical Background:

This case reflects evolving interpretations of psychological incapacity in Philippine law. Initially treated with strict requirements for medical proof, recent decisions, including this one, highlight a more holistic view, considering the total context and evidence beyond medical diagnoses. The Court’s approach underscores the dynamic understanding of personal relations within legal frameworks, signifying a shift towards a more nuanced examination of psychological incapacity under Article 36 of the Family Code.


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