MARIA CONCEPCION N. SINGSON A.K.A. CONCEPCION N. SINGSON, PETITIONER, VS. BENJAMIN L. SINGSON, RESPONDENT.

Singson versus Singson

The Case

This is a petition for review on certiorari brought by Maria Concepcion N. Singson, also known as Concepcion N. Singson, against her husband Benjamin L. Singson. The petitioner sought the declaration of nullity of their marriage on the ground of the respondent's psychological incapacity under Article 36 of the Family Code. The case matters because it is a working illustration of how the Supreme Court applies the settled requisites of gravity, juridical antecedence, and incurability to a spouse diagnosed with pathological gambling and a personality disorder, and because it restates the constitutional and statutory presumption in favor of the validity of marriage and the burden of proof that rests on the petitioner.

Procedural History

The petitioner filed her petition for declaration of nullity of marriage before the Regional Trial Court of Parañaque City, Branch 260. After trial, the Regional Trial Court granted the petition in its Decision of November 12, 2010, declaring the marriage void ab initio on the ground of the respondent's psychological incapacity. The respondent moved for reconsideration, which the trial court denied in its Order of January 6, 2011. The respondent then filed a Notice of Appeal, which the trial court gave due course.

On appeal, the Court of Appeals, in its Decision of August 29, 2013, reversed and set aside the trial court's decision and dismissed the petition for declaration of nullity. The petitioner moved for reconsideration, but the Court of Appeals denied it in its Resolution of January 6, 2014. The petitioner then elevated the matter to the Supreme Court through a Petition for Review on Certiorari.

Facts

On July 6, 1974, Maria Concepcion N. Singson and Benjamin L. Singson were married at St. Francis Church in Mandaluyong, Rizal. Their marriage produced four children, all of whom are now of legal age. When they started living together, the petitioner noticed that the respondent was dishonest, unreasonably extravagant at the expense of the family's welfare, extremely vain physically and spiritually, and a compulsive gambler. She described him as immature, irresponsible, an easy-going man, and guilty of infidelity, and said that his abnormal behavior made him completely unable to render any help, support, or assistance to her, so that she was compelled to work doubly hard as the sole breadwinner.

At the time she filed her petition, the respondent was confined at the Metro Psych Facility, a rehabilitation institution in Pasig City. His attending psychiatrist, Dr. Benita Sta. Ana-Ponio, diagnosed him as suffering from pathological gambling, manifested by preoccupation with gambling, stealing and pawning jewelries and appliances, lying to conceal his involvement, forging his wife's signature, and issuing bouncing checks to finance his gambling. She also found an enduring and inflexible pattern of behavior deviating markedly from cultural expectations, which she diagnosed as a personality disorder, and concluded that all these, put together, hinder the respondent from performing his marital obligations. The petitioner claimed that the respondent had been betting on jai alai even as a high school student, and that she tried but failed to adjust to his personality disorders.

In his Answer, the respondent countered that the requisites of gravity, juridical antecedence, and incurability were not present. He averred that the family home stood on his own capital property, that he had a college degree in business administration and was a bank employee, and that it was money problems, not any personality disorder, that divided them. He waived his right to present countervailing evidence, and the trial court submitted the case for decision.

Issues

• Whether or not the Court of Appeals erred in reversing the decision of the Regional Trial Court declaring the marriage void ab initio on the ground of psychological incapacity.
• Whether or not the petitioner proved that the respondent's psychological incapacity was grave and serious within the meaning of the jurisprudential parameters.
• Whether or not the petitioner proved that the respondent's psychological incapacity existed at the time of the celebration of the marriage.
• Whether or not the petitioner proved that the respondent's psychological incapacity was incurable.

Applicable Provisions

Article 36 of the Family Code provides:

Article 36. A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization. (As amended by Executive Order 227)

This is the sole ground invoked by the petitioner, and the Court measures her evidence against its settled interpretation.

Article 1 of the Family Code, as described in the decision, provides:

Article 1. Marriage is a special contract of permanent union between a man and a woman entered into in accordance with law for the establishment of conjugal and family life. It is the foundation of the family and an inviolable social institution whose nature, consequences, and incidents are governed by law and not subject to stipulation, except that marriage settlements may fix the property relations during the marriage within the limits provided by this Code.

This provision grounds the presumption in favor of the validity and continuance of marriage that the petitioner must overcome.

Article 68 of the Family Code, as cited in the decision, provides:

Article 68. The husband and wife are obliged to live together, observe mutual love, respect and fidelity, and render mutual help and support.

These are the essential marital covenants that a finding of psychological incapacity must show the party to be truly incognitive of.

Ruling

On the first issue, the Court held that the petition will not succeed. It stressed that the validity of marriage and the unity of the family are enshrined in the Constitution and statutory laws, so any doubts are to be resolved in favor of the continuance and validity of the marriage, and the burden of proving nullity rests at all times upon the petitioner.

On the second issue, the Court agreed with the Court of Appeals that the evidence did not establish that the respondent's psychological incapacity was grave and serious. The Court quoted the appellate court's finding that the respondent had a job, provided money for the family from the sale of his property, provided the land where the family home was built, and lived in the family home with the petitioner and their children. The petitioner herself testified that the respondent was working at a certain point, and the Court noted that the parties met at the bank where the respondent was employed as a credit investigator. The Court also noted the notarized summary showing that around 2.9 million pesos in proceeds from the respondent's share in the sale of his parents' home in Magallanes, Makati City paid for the children's education, association dues, and electric bills, and the petitioner's admission that the respondent provided the land on which the family home was built.

On the third issue, the Court found that the alleged pathological gambling arose after the marriage. The petitioner admitted that she was not aware of any gambling by the respondent before they got married, and acknowledged that he was a kind and caring person when he was courting her and that he brought her to the hospital during all four instances when she gave birth to their four children.

On the fourth issue, the Court found that the respondent's purported pathological gambling was not proven to be incurable or permanent, since he had been undergoing treatment since 2003 and had been responding to that treatment.

Doctrine

Psychological incapacity under Article 36 of the Family Code must refer to no less than a mental, not merely physical, incapacity that causes a party to be truly incognitive of the basic marital covenants of living together, observing mutual love, respect and fidelity, and rendering mutual help and support. It must be characterized by gravity, meaning it must be grave and serious such that the party would be incapable of carrying out the ordinary duties required in a marriage; by juridical antecedence, meaning it must be rooted in the history of the party antedating the marriage, although the overt manifestations may emerge only after the marriage; and by incurability, meaning it must be incurable, or even if it were otherwise, the cure would be beyond the means of the party involved.

Mere difficulty, refusal, or neglect in the performance of marital obligations, or ill will on the part of a spouse, is different from an incapacity rooted in some debilitating psychological condition or illness. Any doubt must be resolved in favor of the existence and continuation of the marriage and against its dissolution and nullity, and the burden of proving nullity rests at all times upon the petitioner.

Disposition

The Supreme Court denied the petition and affirmed the Court of Appeals, so the respondent prevailed and the petition for declaration of nullity of marriage was dismissed.

Remember This

Memorize the triad: psychological incapacity must be grave, must have juridical antecedence, and must be incurable, and the burden of proving all three rests on the petitioner against a presumption favoring the validity of the marriage. Examiners use this case to test whether a candidate can distinguish a genuinely grave personality disorder from mere difficulty, neglect, or ill will in the performance of marital obligations.