Atty.

Joanne Manalo- Law on Persons

Tan-Andal v. Andal
G.R. No. 196359 | May 11,2021
Justice Marvic Leonen

In 2000, Rosanna and Mario had separated and had not lived together. Mario also failed to give support
to Rosanna and Ma. Samantha. These events, according to Rosanna, showed Mario's psychological
FACTS:
antagonistic that the only result of the union would be the inevitable and irreparable breakdown of the
incapacity to comply with his essential marital obligations to her. To prove this, Rosanna presented Dr.
marriage. (petitioner) and Mario Andal (respondent) got married in 1995, and Rosanna gave birth to
Rosanna
Garcia, aTan physician-psychiatrist, as an expert witness. Dr. Garcia found Rosanna "psychologically
Samantha
capacitated the
With respecttoto following
comply year.
gravity,with After
her four years
essential
the requirement of marriage,
ismarital
retained, not inthey
obligations."the separated
As forthat
sense in
Mario, 2000. Mariodiagnosed
Dr. Garcia
psychological filed a petition
incapacity him
must
in 2001
with asking
narcissistic for Ma. Samantha’s
antisocial personalitycustody before
disorder the
and Regional
substance Trial
abuse
be shown to be a serious or dangerous illness, but the incapacity is caused by a genuinely serious Court (RTC),
disorder while
with Rosanna
psychotic filed
features. a
Petition
Mario's for Declaration
psychic narcissistic
cause. of Nullity of Her Marriage in 2003, claiming that
antisocial personality disorder, which Dr. Garcia found to be grave, with juridical Mario was psychologically
incapacity
antecedence, of complying
and incurable, with allegedly
his essential maritalMario
rendered obligations to her. incapacitated to comply with his
psychologically
The SC further ruled that the only obligations
essential marital obligation to Rosanna. However, Mario contended that constitute a validthatmarriage
it was are those who
Rosanna that wasexist
According
between to Rosanna,
the spouses. prior to
When a their wedding,
couple has Mariothough,
children, alreadytheir showed duties signs
to of odd
the behavior.
children become (1) part
Whileof
psychologically incapacitated.
they
theirwere
spousaltogether, she noticed
obligations to onethat thereMoreover,
another. were times when
it is made Mario
clearwould
that not be all
unaccounted
kinds of failure for atowhole
meet
night
Mario or an entire
and Rosanna's
their obligations day. (2)
marriage
to their Mario
children once
was will told
declared her
render the of a plan
voidvinculum to
by the RTC.blow
between up a
However, ship to get
the Court
the spouse’s back at
of In
void. a Taiwanese
Appeals (CA)it
each case,
national
must bewho
reversed hadshown
the RTC's
clearly cheated
decision
thatonand
ithis friend
of suchinatheir
isdeclared agrievous
business
marriage deal.
natureto(3)be After
thatsubsisting.Mario’s
it reflects Iton return
concluded from
the capacity thatItaly, Rosanna
Dr.one
of Garcia's
of the
noticed that
psychiatric Mario
evaluation
spouses for marriage. alwaysof went
Mario's outwas at night, would
"unscientific come
and back
unreliable" home sinceat dawn,
she madeand had
her difficulty
diagnosis
managing his finances.Mario.
without interviewing (4) There Rosanna wereconsequently
times when Mario would
petitioned theallegedly
SupremebeCourt extremely
(SC) for irritable
reviewand on
Hence, causing
moody, the SC Rosanna
certiorari. finds Mario to haveto be psychologically
second thoughts about incapacitated
marrying him. to comply with his essential marital
obligations. Rosanna discharged the burden of proof by providing clear and convincing evidence. Expert
Despite
ISSUE:
witnessesthese,
do notRosanna
testifychose
in court to accept
becauseMario for personal
of their who he is, especiallyofgiven
knowledge that of
the facts she thewascase.already
Their
pregnant before they got married.
credibility is due to their special knowledge, skill, experience, or training. It also cannot be said Dr.
Whether or not the marriage between Mario and Rosanna is void due to psychological incapacity.
Garcia’s evaluation
However, during their of Mario
marriage,was exclusively
Mario continued based on collateral
with information
his emotional because itirresponsibility,
immaturity, was also based
on a personal
RULING:
irritability, andhistory handwritten
psychological by Mario
imbalance: (1)himself
He would while staying
leave theirat house
Seagulls, for“independent
several days evidence.
without
Therefore,
informing the
Rosanna CA erred
of his in not giving credence to Dr. Garcia's expert opinion just because Mario
and did not
YES. The SC modified the whereabouts.
doctrine enunciated Once heinreturned
Republichome, vs. Court he would
of Appeals refuse and toMolina
go out ("Molina").
would
appear
sleep forfor
days.psychiatric
(2) Mario evaluation.
admitted that hepsychological
was using marijuana. (3) itMario
To understand what truly constitutes incapacity, tookwas a morenot able to assist Rossana
comprehensive but
during
nuanced their
Additionally, child’s birth.
the SCtaking
approach, agreesinto(4) Mario
withaccount showed
the RTC thethat symptoms of
Mario is incapable
inconsistencies paranoia.
in which He thought
of performing
the doctrinehis everyone
downwas
marital
laid out to
obligations,
in Molina
attack himapplied.
particularly
has been and, at times,love
to observe would andhide Ma. Samantha
respect for his wife from
andthose he thought
to render mutualwere helpoutandtosupport.
hurt them. He (5)had
Mario would also take large cash advances from their business
shown utter disregard for his wife, as throughout their life together, it was Rosanna who mostly every week. Rosanna only learned this
The SCanruled
when that the personnel
plaintiff-spouse musther prove histhe
or her
firmcase with noclear and payconvincing evidence.
provided accounting
for the needs informed
of the family. Mario hardly that contributed could to their longer
expenses the construction
because he never
This is more
workers' than the (6)a preponderance of evidence but lessfeverthanand proof beyond reasonable doubt. This is
botheredsalaries.
to look for When
job. And Ma.heSamantha
was also using had dengue
prohibited drugs. had to be confined at the hospital,
the quantum
Mario prevented of theproof
nurses required for the plaintiff-spouse
from administering the prescribed to prove
medicationsthe existence of psychological
to Ma. Samantha. He also
Thus,
did notthe
incapacity.
cleanpetition
The for her
up reason
after review thatonthere
is vomit certiorari
and is a was
ignored thegranted
presumption
child and by the
theSC.
of continued Thesleeping.
validity marriage (7)between
of marriages, Marioand Mario
was such
foundand
a
Rosanna
presumption declared
can void.
only be rebutted with clear and convincing evidence.
positive for drug use after a doctor conducted tests on him and advised him to commit him to a drug
rehabilitation
The second Molina centerguideline
for treatment. (8) Rosanna
is categorically had to by
abandoned closetheher SC. business
It was stated due to thatfinancial losses
psychological
because
incapacityMario's
is neitheraccess to the company
a mental incapacityfunds nor afor his drug use
personality allegedly
disorder that used
must up be the funds.
proven (9) Rosanna
through expert
petitioned the RTC to voluntarily commit Mario for drug rehabilitation
opinion. There must be proof, however, of the durable or enduring aspects of a person's personality, at the National Bureau of
Investigation
called "personalityTreatment and Rehabilitation
structure," which manifests Centeritselfand, eventually,
through clear at theacts Seagulls Flight Foundation;
of dysfunctionality that
however, Mario escaped from the latter, returning home, and
undermine the family. The spouse's personality structure must make it impossible for him or her to pleading with Rosanna to take him in
again. Rosanna
understand and, took
more herimportantly,
husband in, to butcomply
Mario wouldwith his again
or herrelapse into drug
essential maritaluse.obligations.
He was alsoProof jobless of
and could not support his family. (10) When Ma. Samantha again
these aspects of personality does not need to be given by an expert. Ordinary witnesses who have been had a severe upper respiratory tract
infection
present in andthefrequent
lives of vomiting,
the spouses andbefore
whenthe herlatter
nannycontracted
was aboutmarriage to give her may medicine,
testify to Mario prevented
behaviors that
the nanny from doing so, saying that mangoes
they have consistently observed in the supposedly incapacitated spouse.would cure Ma. Samantha.

As to the juridical antecedence requirement, a party to a nullity case is still required to prove it because
itFrancisco,
is an explicit requirement
Sheena Kristill A. | Legal under Article 36.
Management-2A | CaseAsDigest
such, evidence of the juridically antecedent
psychological incapacity may consist of testimony on the spouse's past experiences that may have led
them to their psychological incapacity.