Vinas vs. Vinas DIGEST

VINAS VS. VINAS (G.R. No. 208790, January 21 2015)

5. On the other hand, Dr. Tayag assessed Mary Grace’s  personality through the data she had gathered from Glenn and his cousin, Rodelito Mayo (Rodelito), who knew Mary Graceway back in college.

1. On April 26, 1999, Glenn and Mary Grace, then 25 and 23 years old, respectively, got married in civil rites held in Lipa City, Batangas.4 Mary Grace was already pregnant then. The infant, however, died at birth due to weakness and malnourishment. Glenn alleged that the infant’s death was caused by Mary Grace’s heavy drinking and smoking during her pregnancy.

6. Dr. Tayag diagnosed Mary Grace to be suffering from a  Narcissistic Personality Disorder with anti-social traits. Dr. Tayag concluded that Mary Grace and Glenn’s relationship is not founded on mutual love, trust, respect, commitment and fidelity to each other.

FACTS

2. In March of 2006, Mary Grace left the conjugal abode. Glenn found out after that Mary Grace went to work in Dubai. At the time the petition was filed Mary Grace had not returned yet. 3. On February 18 2009 Glenn filed a petition for the declaration of nullity of of his marriage with Mary Grace. Grace. He alleged that Mary Grace was insecure, extremely jealous, outgoing and prone to regularly resorting to any pretext to be able to leave the house. She thoroughly enjoyed the night life, and drank and smoked heavily even when she was pregnant. Further, Mary Grace refused to perform even the most essential household chores of cleaning and cooking.

7. On January 29, 2010, the RTC rendered its Decision declaring the marriage between Glenn and Mary Grace as null and void on account of the latter’s psychological inca pacity. inca pacity. 8. On January 29, 2013, the CA rendered the herein assailed decision reversing the RTC ruling and declaring the marriage  between Glenn and Mary Grace as valid and subsisting, citing the case of Santos vs CA where "psychological incapacity" should refer to no less than a mental (not physical) incapacity that causes a party to be truly incognitive of the basic marital covenants.

ISSUE

WON Mary Grace was psychologically incapacitated 4. Glenn sought professional guidance and submitted himself to a psychological evaluation by Clinical Psychologist Nedy Tayag (Dr. Tayag). Dr. Tayag found him as "amply aware of his marital roles" and "capable of maintaining a mature and healthy heterosexual relationship.

HELD

the respondent’s narcissistic personality disorder and to prove that it existed at the inception of the marriage.

NO.

While it is true that Glenn’s testimony was corroborated by Dr. Tayag, a psychologist who conducted a psychological examination on Glenn, however, said examination was conducted only on him and no evidence was shown that the  psychological incapacity of Mary Grace was characterized by gravity, juridical antecedence, and incurability. It would be great injustice, to petitioner for the Court to give a much too restrictive interpretation of the law and compel the  petitioner to continue to be married to a wife who for purposes of fulfilling her marital duties has, for all practical purposes, ceased to exist

First, what she medically described was not related or linked to the respondent’s exact condition except in a very general way. Second, her testimony was short on factual basis for her diagnosis because it was wholly based on what the petitioner related to her. The totality of the evidence presented provides inadequate  basis for the Court to conclude that Mary Grace is indeed  psychologically incapacitated to comply with her obligations as Glenn’s spouse. The petition is DENIED

The cumulative testimonies of Glenn, Dr. Tayag and Rodelito, and the documentary evidence offered do not sufficiently prove the root cause, gravity and incur ability of Mary Grace’s condition. The respondent’s stubborn refusal to cohabit with the petitioner was doubtlessly irresponsible, but it was never  proven to be rooted in some psychological illness. Dr. Tayag’s conclusions about the respondent’s psycholog ical incapacity were based on the information fed to her by only one side  –   the petitioner  –   whose bias in favor of her cause cannot be doubted. The court finds that Dr. Tayag’s observations and conclusions insufficiently in-depth and comprehensive to warrant the conclusion that a psychological incapacity existed that  prevented the respondent from complying with the essential obligations of marriage. It failed to identify the root cause of