Te vs Te

Te vs. Te

GR No. 161793, February 13, 2009

FACTS:

Petitioner Edward Te first met respondent Rowena Te in a gathering organized by the Filipino-Chinese association in their college.  Initially, he was attracted to Rowena’s close friend but, as the latter already had a boyfriend, the young man decided to court Rowena, which happened in January 1996.  It was Rowena who asked that they elope but Edward refused bickering that he was young and jobless.  Her persistence, however, made him relent.  They left Manila and sailed to Cebu that month; he, providing their travel money of P80,000 and she, purchasing the boat ticket.

They decided to go back to Manila in April 1996. Rowena proceeded to her uncle’s house and Edward to his parents’ home. Eventually they got married but without a marriage license.  Edward was prohibited from getting out of the house unaccompanied and was threatened by Rowena and her uncle.  After a month, Edward escaped from the house, and stayed with his parents.  Edward’s parents wanted them to stay at their house but Rowena refused and demanded that they have a separate abode.  In June 1996, she said that it was better for them to live separate lives and they then parted ways.

After four years in January 2000, Edward filed a petition for the annulment of his marriage to Rowena on the basis of the latter’s psychological incapacity.

ISSUE: Whether the marriage contracted is void on the ground of psychological incapacity.

HELD:

The parties’ whirlwind relationship lasted more or less six months. They met in January 1996, eloped in March, exchanged marital vows in May, and parted ways in June. The psychologist who provided expert testimony found both parties psychologically incapacitated. Petitioner’s behavioral pattern falls under the classification of dependent personality disorder, and respondent’s, that of the narcissistic and antisocial personality disorder

There is no requirement that the person to be declared psychologically incapacitated be personally examined by a physician, if the totality of evidence presented is enough to sustain a finding of psychological incapacity.  Verily, the evidence must show a link, medical or the like, between the acts that manifest psychological incapacity and the psychological disorder itself.

The presentation of expert proof presupposes a thorough and in-depth assessment of the parties by the psychologist or expert, for a conclusive diagnosis of a grave, severe and incurable presence of psychological incapacity.

 Indeed, petitioner, afflicted with dependent personality disorder, cannot assume the essential marital obligations of living together, observing love, respect and fidelity and rendering help and support, for he is unable to make everyday decisions without advice from others, and allows others to make most of his important decisions (such as where to live).  As clearly shown in this case, petitioner followed everything dictated to him by the persons around him. He is insecure, weak and gullible, has no sense of his identity as a person, has no cohesive self to speak of, and has no goals and clear direction in life.

As for the respondent, her being afflicted with antisocial personality disorder makes her unable to assume the essential marital obligations on account for her disregard in the rights of others, her abuse, mistreatment and control of others without remorse, and her tendency to blame others.  Moreover, as shown in this case, respondent is impulsive and domineering; she had no qualms in manipulating petitioner with her threats of blackmail and of committing suicide.

Both parties being afflicted with grave, severe and incurable psychological incapacity, the precipitous marriage that they contracted on April 23, 1996 is thus, declared null and void.