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Halili v.
Halili G.R. No. 165424 June 6, 2009
FACTS: ● This resolves the motion for reconsideration of the April 16, 2008 resolution of this Court denying petitioner's petition for review on certiorari (under Rule 45 of the Rules of Court). The petition sought to set aside the January 26, 2004 decision and September 24, 2004 resolution of the Court of Appeals (CA) in CA-G.R. CV No. 60010.
● Petitioner Lester Benjamin S. Halili filed a petition to declare his marriage to respondent Chona M. Santos-Halili null and void on the basis of his psychological incapacity to perform the essential obligations of marriage in the Regional Trial Court (RTC), Pasig City, Branch 158. He alleged that he wed respondent in civil rites thinking that it was a joke.
● After the ceremonies, they never lived together as husband and wife, but maintained the relationship. However, they started fighting constantly a year later, at which point petitioner decided to stop seeing respondent and started dating other women. Immediately thereafter, he received prank calls telling him to stop dating other women as he was already a married man. It was only upon making an inquiry that he found out that the marriage was not fake.
● Eventually, the RTC found petitioner to be suffering from a mixed personality disorder, particularly dependent and self-defeating personality disorder, as diagnosed by his expert witness, Dr. Natividad Dayan.
● The court a quo held that petitioners personality disorder was serious and incurable and directly affected his capacity to comply with his essential marital obligations to respondent. It thus declared the marriage null and void.
● On appeal, the CA reversed and set aside the decision of the trial court on the ground that the totality of the evidence presented failed to establish petitioners psychological incapacity. Petitioner moved for reconsideration. It was denied.
● The case was elevated to the Supreme Court via a petition for review under Rule 45. We affirmed the CAs decision and resolution upholding the validity of the marriage. Petitioner then filed this motion for reconsideration reiterating his argument that his marriage to respondent ought to be declared null and void on the basis of his psychological incapacity. He stressed that the evidence he presented, especially the testimony of his expert witness, was more than enough to sustain the findings and conclusions of the trial court that he was and still is psychologically incapable of complying with the essential obligations of marriage.
ISSUE: 1. Whether or not, psychological incapacity of the petitioner is a sufficient ground for nullity of marriage. 2. Whether or not the decision of the Regional Trial Court should be reinstated.
HELD: Court reiterated that courts should interpret the provision on psychological incapacity (as a ground for the declaration of nullity of a marriage) on a case-to-case basis guided by experience, the findings of experts and researchers in psychological disciplines and by the decisions of church tribunals. In Te, this Court defined dependent personality disorder as: “a personality disorder characterized by a pattern of dependent and submissive behavior. Such individuals usually lack self-esteem and frequently belittle their capabilities; they fear criticism and are easily hurt by others comments. At times they actually bring about dominance by others through a quest for overprotection”
1. In her psychological report, Dr. Dayan stated that petitioners dependent personality disorder was evident in the fact that petitioner was very much attached to his parents and depended on them for decisions. Petitioners mother even had to be the one to tell him to seek legal help when he felt confused on what action to take upon learning that his marriage to respondent was for real.
Ultimately, Dr. Dayan concluded that petitioners personality disorder was grave and incurable and already existent at the time of the celebration of his marriage to respondent
2. From the foregoing, it has been shown that petitioner is indeed suffering from psychological incapacity that effectively renders him unable to perform the essential obligations of marriage. Accordingly, the marriage between petitioner and respondent is declared null and void. The decision of the Regional Trial Court, Pasig City, Branch 158 dated April 17, 1998 is REINSTATED.
