Civil Law,  Legally Yours

Republic v. De Gracia

Civil Law. Persons and Family Relations.  Article 36 Family Code. Psychological Incapacity.
Republic v. De Gracia
G.R. No. 171557; February 12, 2014

FACTS:
Rodolfo and Natividad were married on February 15, 1969 at a church in Zamboanga Del Norte. On December 25, 1998, Rodolfo filed a verified complaint for the declaration of nullity of marriage alleging that Natividad was psychologically incapacitated to comply with her essential marital obligations. Petitioner furthered that he was forced to marry her barely 3 months into their courtship in light of her accidental pregnancy. He was 21, she was 18. Natividad left their conjugal abode and sold their house without his consent. Thereafter, she lived with a certain Engineer Terez. After cohabiting with Terez, she contracted a second marriage with another man. Dr. Zalsos stated that both Rodolfo and Natividad were psychologically incapacitated finding that both parties suffered from “utter emotional immaturity”.

ISSUE:
Did the Court of Appeals err in sustaining the RTC’s finding of psychological incapacity?

HELD:
The petition is meritorious. There exists insufficient factual or legal basis to conclude that Natividad’s emotional immaturity, irresponsibility, or even sexual promiscuity, can be equated with psychological incapacity. The RTC relied heavily on Dr. Zalsos testimony which does not explain in reasonable detail how Natividad’s condition could be characterized as grave, deeply-rooted and incurable within the parameters of psychological incapacity jurisprudence. The petition is, therefore, granted and the decision of CA reversed and set aside.

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