Siayngco vs. Siayngco, G.R. No. 158896, October 27, 2004

86. Siayngco vs. Siayngco, G.R. No.
158896, October On the other hand, sexual intimacy for procreation is a

27, 2004 non-issue herein.
FACTS: Rather, we have here a case of a husband who is

constantly embarrassed by his wife’s outbursts and
Petitioner Juanita Carating-Siayngco ("Petitioner overbearing ways,
Juanita") and respondent Manuel were married a
It was in Santos v. Court of Appeals42 where we declared
after twenty-four (24) years of married life together, that "psychological incapacity" under Article 36 of the
respondent Manuel filed for the declaration of its nullity Family Code is not meant to comprehend all possible
on the ground of psychological incapacity of petitioner cases of psychoses.
Juanita.
It should refer, rather, to no less than a mental (not
He alleged that physical) incapacity that causes a party to be truly
incognitive of the basic marital covenants that
1. all throughout their marriage, his wife exhibited concomitantly must be assumed and discharged by the
an over domineering and selfish attitude parties to the marriage.
towards him which was exacerbated by her
extremely volatile and bellicose nature; Psychological incapacity must be characterized by (a)
gravity, (b) juridical antecedence, and (c) incurability. 43
2. that she incessantly complained about almost In Republic v. Court of Appeals44 we expounded:
everything and anyone connected with him
In Republic v. Court of Appeals44 we expounded:
3. that she showed no respect or regard at all for
the prestige and high position of his office as
(1) The burden of proof to show the nullity of
judge of the Municipal Trial Court;
marriage belongs to the plaintiff.
4. that her psychological incapacity arose before
(2) The root cause of the psychological incapacity
marriage, rooted in her deep-seated resentment
must be: a) medically or clinically identified, b)
and vindictiveness for what she perceived as
alleged in the complaint, c) sufficiently proven by
lack of love and appreciation from her own
experts and d) clearly explained in the decision.
parents since childhood and that such incapacity
Article 36 of the Family Code requires that the
is permanent and incurable
incapacity must be psychological – not physical,
although its manifestations and/or symptoms may
petitioner Juanita alleged that respondent Manuel
be physical.
invented malicious stories against her so that he could
be free to marry his paramour; (3) The incapacity must be proven to be existing at
the "time of the celebration" of the marriage.
2 psychiatrists were admitted, and both of whom
declared parties that parties are not psychologically (4) Such incapacity must also be shown to be
incapacitated. medically or clinically permanent or incurable.
court denied respondent Manuel’s petition for (5) Such illness must be grave enough to bring about
declaration of nullity of his marriage to petitioner Juanita the disability of the party to assume the essential
because the asserted psychological incapacity of the obligations of marriage.
defendant is not preponderantly supported in evidence
(6) The essential marital obligations must be those
ISSUE: WON, the court erred in denying the petition? embraced by Articles 68 up to 71 of the Family
Code as regards the husband and wife as well as
Articles 220, 221 and 225 of the same Code in
regard to parents and their children. Such non-
RULING: NO complied marital obligation(s) must also be stated
whether or not psychological incapacity exists in a given in the petition, proven by evidence and included in
the text of the decision.
case calling for the declaration of the nullity of the
marriage depends crucially on the facts of the case.
from the totality of the evidence adduced by both
The Court of Appeals perfunctorily applied our ruling in parties, we have been allowed a window into the
Chi Ming Tsoi despite a clear divergence in its factual Siayngcos’s life and have perceived therefrom a simple
milieu with the case at bar. case of a married couple drifting apart, becoming
strangers to each other, with the husband consequently
In Chi Ming Tsoi, the couple involved therein, despite falling out of love and wanting a way out.
sharing the same bed from the time of their wedding
night on 22 May 1988 until their separation on 15 March An unsatisfactory marriage, however, is not a null and
1989, never had coitus.
void marriage. Mere showing of "irreconcilable
differences" and "conflicting personalities" in no wise
The perplexed wife filed the petition for the declaration constitutes psychological incapacity.59
of the nullity of her marriage on the ground of
psychological incapacity of her husband.

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86. Siayngco vs. Siayngco, G.R. No.

158896, October On the other hand, sexual intimacy for procreation is a

FACTS: Rather, we have here a case of a husband who is

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