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Jocelyn filed for annulment of her marriage to Angelito due to psychological incapacity. The court ruled against the annulment for three reasons: 1) The psychologist evaluated Angelito indirectly and based conclusions solely on information from the biased Jocelyn rather than directly examining Angelito; 2) The psychologist failed to conclusively determine the root cause, gravity, and incurability of Angelito's alleged condition as required; 3) Jocelyn's testimony of Angelito's bad behaviors did not prove psychological incapacity on its own and there was no evidence linking the behaviors to an underlying psychological disorder.
Originalbeschreibung:
Case Law
Originaltitel
Jocelyn Suazo vs Angelito Suazo and Republic of the Philippines Gr
Jocelyn filed for annulment of her marriage to Angelito due to psychological incapacity. The court ruled against the annulment for three reasons: 1) The psychologist evaluated Angelito indirectly and based conclusions solely on information from the biased Jocelyn rather than directly examining Angelito; 2) The psychologist failed to conclusively determine the root cause, gravity, and incurability of Angelito's alleged condition as required; 3) Jocelyn's testimony of Angelito's bad behaviors did not prove psychological incapacity on its own and there was no evidence linking the behaviors to an underlying psychological disorder.
Jocelyn filed for annulment of her marriage to Angelito due to psychological incapacity. The court ruled against the annulment for three reasons: 1) The psychologist evaluated Angelito indirectly and based conclusions solely on information from the biased Jocelyn rather than directly examining Angelito; 2) The psychologist failed to conclusively determine the root cause, gravity, and incurability of Angelito's alleged condition as required; 3) Jocelyn's testimony of Angelito's bad behaviors did not prove psychological incapacity on its own and there was no evidence linking the behaviors to an underlying psychological disorder.
FACTS: Angelito and Jocelyn married each other in their early age. They are 16 yrs old when they met each other. They were gone for three days and after their parents found them they arranged their marriage. Angelito and Jocelyn do not have any means to support themselves thus they lived with Angelitos parents after their marriage. They did not finish their studies. Jocelyn took odd jobs such as working as a Household helper in the relatives of Angelito, while the latter refused to work and instead preferred to be a drunkard. They had several quarrels and as a consequence of which Jocelyn left Angelito. After 10 yrs Jocelyn filed a petition for declaration of nullity of the marriage under Article 36 of the family Code. She contends that Angelito was psychologically incapacitated to comply with the essential obligations of marriage. Angelito did not answer to the petition and complaint. Neither did he submit himself to a psychological examination with a psychologist Nedy Tayag who was hired by Jocelyn. Issue: Whether there is a basis to nullify Jocelyns marriage with Angelito under Article 36 of the Family Code. Ruling: No, there is no basis. Even if pursuant to Hernandez v. CA and Marcos v. Marcos there is no need to be declared a psychologically incapacitated to be personally examined If the totality of the 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. Accordingly emphasizing that 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;
According to Supreme Court under the evolutionary development of cases
it was shown that even if psychological incapacity is decided on a case to case basis, the controlling doctrine would still be the Santos which reiterates Juridical antecedence, gravity, and incurability. In the present case, the court finds no basis because both psychologists testimony and the psychological report did not conclusively show the root cause, gravity and incurability of Angelitos alleged psychological condition on the ground that the psychologist evaluated Angelitos psychological condition only in an indirect manner. The psychologist derived her conclusions from the information coming from Jocelyn whose bias for her cause cannot of course be doubted. The court must evaluate the evidentiary information with due care and with the application of more rigid and stringent set of standards. Personal examination is not mandatory, but for the determination of Angelitos complete personality profile information coming from the persons intimately related to him may be helpful. This is the flexibility emphasized in Article 36. The psychologist therefore failed to provide the answers to the more important concerns or requisites of psychological incapacity, all of which are critical to the more important concerns or requisites of psychological incapacity. Jocelyns testimony is also insufficient by merely testifying on Angelitos habitual drunkness, gambling, refusal, to seek a employment and physical beating she received from him. These actions of Angelito do not constitute psychological incapacity. All of these simply indicate difficulty, neglect or mere refusal to perform marital obligations that, as cited jurisprudence holds cannot be considered to be constitutive of psychological incapacity in the absence of proof that these are manifestations of incapacity in some debilitating psychological condition or illness. Jurisprudence holds that there must be evidence showing a link, medical or the like, between the acts that manifest psychological incapacity and psychological disorder itself. The evidence of this nexus is irretrievably lost in the present case because the opinion of the psychologist cannot be relied upon.
Fed. Sec. L. Rep. P 96,317 Louise Price Parsons v. Hornblower & Weeks Hemphill, Noyes, a Partnership, Howard E. Buhse, Charles L. Morse, Jr., Jansen Noyes, Jr., William J. Lawlor, Jr., William G. Maloney, George T. Flynn, Blancke Noyes, Walker W. Stevenson, Jr., Clifton P. Walker, James F. Gilbert, Robert R. Miller, Ralph L. Pope, Jr., Robert W. Sharer, George N. Morris, Henry Hornblower, Ii, Ralph Hornblower, Jr., Harold F. Carter, Joseph A. Gimma, Robert R. Spence, Hatfield Smith, Dudley H. Bradlee, Ii, Eugene M. Matalene, J. Malcolm De Sieyes, Edmund T. Anderson, Herman H. Kuver, Stephen C. Reynolds, Jr., Clifford Hemphill, Jr., Richard A. Miller, John F. Detmer, Thor W. Kolle, Jr., Pearce D. Smith, A. Paul Ogilvie, Jr., Jack P. Gould, Royal G. Whiting, C. Austin Barker, Joseph R. Carson, Milton J. Rusnak, Robert M. Wholforth, James M. Clark, Elmer I. Paull, Henry F. Williams, Stephen J. Kozeletz, John P. Toolan, John T. Schriver, James F. Clardy, William G. Budinger, Salvatore Sala
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