3 - Katipunan V Tenorio

 

Katipunan v. Tenorio  38 OG 172, 1937 

Facts:  Marcos Katipunan and Rita Tenorio had been married for seven years. Tenorio suffered a mental ailment. Katipunan wanted to annul their marriage on the ground of insanity.  

Issue:  WON mental ailment after the celebration of the marriage be considered as insanity and as a ground for annulment. 

Held:  There is no ground to annul the marriage. Insanity occurs after the celebration of the marriage does not constitute a  cause for nullity. The wife was mentally sound at the time of the marriage.  

 Note: Definition sa Mental illness is usually a broader and more inclusive term than Insanity. Insanity is usually reserved for describing severe conditions involving psychotic-like breaks with reality, while Mental Illness can include both severe and milder forms of mental problems (such as anxiety disorders and mild depressions). 

The Court is not convinced. It is a legal truism that to overcome a presumption created by law, such as the validity of a marriage and the sanity of the contracting parties, the evidence must be clear, unequivocal, and convincing (Katipunan vs. Tenorio, 38 O.G. 173, Sept. 29, 1937)