BARRIOS, Arjay

BELTRAN, Ayana Jane

EDWARD TE vs. ROWENA TE

G.R. No. 161793
FEBRUARY 13, 2009

FACTS:

Petitioner Edward Kenneth Ngo Te met respondent Rowena Ong Gutierrez Yu-Te in a
gathering by the Filipino-Chinese association in their college. Thereafter, petitioner decided to
court Rowena in January 1996, when petitioner was a sophomore student and respondent, a
freshman.

The two understood one another and developed a certain degree of closeness towards
each other by their common angst on their families, so in March 1996, Rowena asked Edward
that they elope. Her persistence made him relent regardless the refusal at first. They
left Manila and sailed to Cebu that month; he, providing their travel money and she, purchasing
the boat ticket. In the length of their stay, they could not find a job so, in April 1996, they decided
to go back to Manila. Rowena proceeded to her uncle’s house and Edward to his parents’
home. Edward agreed to stay with Rowena at her uncle’s place since and Rowena kept on
telephoning him, threatening him that she would commit suicide,

On April 23, 1996, Rowena’s uncle brought the two to a court to get married. The two
then continued to stay at her uncle’s place where Edward was treated like a prisoner; he was
not allowed to go out unaccompanied. At one point, Edward was able to call home and talk to
his brother who suggested that they should stay at their parent’s home and live with
them. However, Rowena suggested that he should get his inheritance so that they could live on
their own. Edward talked to his father about this, but he told Edward that he would be
disinherited, and insisted that Edward must go home.

After a month, Edward escaped from the house of Rowena’s uncle, and stayed with his
parents. His family then hid him from Rowena and her family whenever they telephoned to ask
for him. In June 1996, Edward was able to talk to Rowena. Unmoved by his persistence that
they should live with his parents, she said that it was better for them to live separate lives. They
then parted ways.

ISSUE:

Whether or not they were granted a judicial declaration of nullity of marriage on the
ground of psychological incapacity?

HELD:

Yes, their marriage was declared null and void.

The Supreme Court ruled that admittedly, the SC may have inappropriately imposed a
set of rigid rules in ascertaining Psychological Incapacity in the Molina case. So much so that
the subsequent cases after Molina were ruled accordingly to the doctrine set therein. And that
there is not much regard for the law’s clear intention that each case is to be treated differently,
as “courts should interpret the provision on a case-to-case basis; guided by experience, the
findings of experts and researchers in psychological disciplines, and by decisions of church
tribunals.” The SC however is not abandoning the Molina guidelines, the SC merely
reemphasized that there is need to emphasize other perspectives as well which should govern
the disposition of petitions for declaration of nullity under Article 36 such as in the case at bar.
The principle that each case must be judged, not on the basis of a priori assumptions,
predilections or generalizations but according to its own facts. And, to repeat for emphasis,
courts should interpret the provision on a case-to-case basis; guided by experience, the findings
of experts and researchers in psychological disciplines, and by decisions of church tribunals.

The Court ruled that, 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 part of 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.

Added to this, 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.

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.