HALILI v.

HALILI
[G.R. No. 165424; June 9, 2009]
PETITIONER: Lester Halili
RESPONDENT:
Chona Halili
PONENTE:
Corona, J.
LAW: Art. 36, Family Code (FC)
FACTS:
This decision resolves the MR of the April 16, 2008 SC resolution which denied petitioners petition to
set aside CA decision (which declared parties marriage as valid)
Petitioner sought to declare his marriage to respondent null and void due to psychological incapacity to
perform the essential obligations of marriage in the RTC Pasig City
o alleged that he wed respondent in civil rites thinking that it was a joke
o After the ceremonies, they never lived together as husband & wife, but maintained the
relationship
o They started fighting constantly a year later, so petitioner stopped seeing respondent and
started dating other women
o He received prank calls telling him to stop dating other women as he was already a married
man
o It was only upon making an inquiry that he found out that the marriage was not fake
RTC declared the marriage null & void
o found petitioner to be suffering from a mixed personality disorder (dependent and self-defeating
personality disorder) as diagnosed by his expert witness, Dr. Dayan
o held that petitioners personality disorder was serious and incurable and directly affected his
capacity to comply with his essential marital obligations to respondent
CA reversed and set aside the RTC decision
o totality of the evidence presented failed to establish petitioners psychological incapacity
o Petitioners MR was denied
SC affirmed CAs decision
o Petitioner filed MR, reiterating his arguments that his evidence, especially the testimony of his
expert witness, was more than enough to sustain the conclusion that he was and still is
psychologically incapable of complying with the essential obligations of marriage
ISSUE:WON the evidence presented is enough to declare him as psychologically incapable of complying
with the essential obligations of marriage
RULING:
YES, it is. Motion for Reconsideration GRANTED. Marriage is NULL & VOID for psychological
incapacity.
petitioners expert witness testified that petitioner was suffering from dependent personality disorder
o Te v. Yu-Te: courts should rule on psychological incapacity (for the declaration of nullity of a
marriage) on a case-to-case basis guided by experience, expert findings in psychological
disciplines and by decisions of church tribunals
o Courts have the burden of making decisions, but we must still consider as essential the expert
opinion on the psychological and mental disposition of the parties
Dr. Dayans testimony:
o He is suffering from a mixed personality disorder from self-defeating to [dependent]
personality disorder (grave, incurable, and already existent at the time of the celebration of
his marriage)
disorder characterized by a pattern of dependent and submissive behavior
lack self-esteem and frequently belittle their capabilities
fear criticism and are easily hurt by others comments
o evident in the fact that petitioner was very much attached to his parents and depended on them
for decisions
o allowed himself to be dominated by his father and, later, by respondent
o brought about by his dysfunctional family (abusive, domineering father; unhappy mother;
children w/o affirmation)
o he also suffered from partner relational problem during his marriage with Chona

His motivation for marriage was very questionable, as it was a very impulsive, spur-of-themoment decision
o He didnt understand what it meant to be married. After the marriage, there was no
consummation, sexual intercourse, or cohabitation. He never thought it was a really serious
matter at all.
o After 3 months, he refused to see or talk with the respondent and the relationship died a natural
death
o they didnt appreciate the civil [rites which] they had undergone or even considered themselves
married
personality disorders are long-standing, inflexible ways of behaving (as dysfunctional styles of
living). These disorders affect all areas of functioning and, beginning in childhood or adolescence,
create problems for those who display them and for others.
o