SC affirms nullification of marriage between ‘psychotic’ husband, ‘greedy, gossiper’ wife


Supreme Court (SC)

Due to a husband’s “hallucinations and delusions as the son of God, and can have many wives” which have become an enduring part of his personality structure, the Supreme Court (SC) affirmed the nullify of his marriage with his wife solemnized 42 years ago.

With its ruling, the SC affirmed the decisions of both the regional trial court (RTC) in 2007 and the Court of Appeals (CA) in 2012. Both courts ruled favorably on the nullity of marriage based on psychological incapacity sought by Alfredo in 2005 against his wife Irene.

(The Manila Bulletin decided not to publish the complete names of the couple who have two children, the place of their marriage, and the branch of the RTC which granted the husband’s petition.)

The SC decision was written by Associate Justice Marvic M.V.F. Leonen and was made public last Feb. 11.

In affirming the CA’s decision which upheld the RTC ruling, the SC said:

“Here, this Court finds that Alfredo is psychologically incapacitated to comply with his essential marital obligations, not because he suffers from schizophrenia per se, but because his psychosis has been found to be an enduring part of his personality structure. This psychosis, in tum, led him to do clear acts of dysfunctionality that undermined Irene and their family.

“As the lower courts found, Alfredo believes himself to be the son of God. In his mind, his refusal to live with Irene and to provide for the family was God's will. He also believes that he can have as many wives as he wants, which is not only illegal but is in utter disrespect and disregard of his marital vow to Irene.

“His incapacity is grave, not a ‘mild characterological peculiarity,’ a ‘mood change,’ or an ‘occasional emotional outburst’; his psychosis was grave enough for him to be discharged from military service.”

During the trial on his petition for marriage nullity, Alfredo testified that he was formerly employed by the United States Navy in 1978. But he said after 14 months in service he was discharge after psychiatric and medical evaluations showed he was suffering from schizophrenia, “a chronic mental disorder characterized by inability to distinguish between fantasy and reality and often accompanied by hallucinations and delusions.”

Alfredo was already discharged from the US Navy when she met Irene who was introduced to him in their church, the Assembly of God. Their acquaintance led them to sleep together one night. When discovered by Irene’s sister, they eventually got married and lived together.

In his petition before the RTC, Alfredo claimed Irene violated her marital covenant because she did not submit to him “as written in the Book of Ephesians.”

(The New International Version of the Bible states: "Wives, submit to your husbands as to the Lord. For the husband is the head of the wife as Christ is the head of the church, his body, of which he is the Saviour.”)

Alfredo also claimed that Irene “became materialistic” and forced him to borrow money to build their conjugal home.

He told the RTC that his utterances come from God and that he was discharged from the US Navy because of his premonition that he would suffer a severe tragedy.

Aside from the testimony of his aunt – who claimed Irene was “inggitera, mukhang pera, tsismosa” (jealous, greedy, gossiper) -- Alfredo offered in evidence the “expert opinion” of clinical psychologist Martha Johanna D. Dela Cruz who conducted a psychological evaluation. He said the psychologist also asked the Irene be evaluated but she declined.

He also offered in evidence the medical certificate on his schizophrenia issued by Dr. Jose Rommel T. Soriano.

Dela Cruz’s evaluation of Alfredo showed that he “did not have any psycho motor agitation but his judgment was impaired." He was also found that his psychosis was due to schizophrenia, paranoid type, and that there was no cure for his psychosis, although was already under medication.

For her part, Irene testified that she separated from Alfredo because her husband has found another woman. Aside from the issue on financial support, she admitted that they have different religious beliefs.

She told the trial court did not want their marriage nullified because the financial support she has been receiving from US Veterans Affairs Office might be cut off. She admitted that the benefit she has been getting from the US Veterans Office was due to her husband’s schizophrenia.

The RTC granted Alfredo’s petition with a ruling that he was psychologically incapacitated to comply with his essential marital obligations to Irene.

The trial court pointed out that the multiple expert opinions Alfredo offered in evidence sufficiently proved that he had schizophrenia even before he married Irene, and that the mental disorder was a manifestation of his psychological incapacity.

Irene asked the RTC for new trial but her plea was denied. She appealed to the CA which upheld the RTC’s ruling. Irene elevated the case to the SC.

In affirming the CA’s decision, the SC said:

“Psychological incapacity, a ground to void marriage under Article 36 of the Family Code, is a legal, not a medical, concept. As such, it is enough that parties prove that an enduring part of their personality renders them incapable of performing their essential marital obligations. That the psychological incapacity be rooted in a particular psychological illness is no longer necessary.

“As a legal concept, psychological incapacity cannot be characterized as incurable. Instead, it is permanent relative to a specific partner. However, psychological incapacity can be grave, not in the sense that it is a serious or dangerous mental illness, but that it excludes ‘mild characterological peculiarities, mood changes, occasional emotional outbursts.’

“The incapacity must be shown to be due to a genuinely serious psychic cause. And, as explicitly required by the law, the incapacity must have existed before or during the celebration of the marriage.

“Here, Irene asks this Court to review the truthfulness of Alfredo's allegation that he was discharged from the United States Navy because of schizophrenia, and that he already had the disorder even before he married her. Irene also assails the assessment, both of the trial court and the Court of Appeals, of the evidence presented by Alfredo, specifically, the written findings of the United States Veterans Affairs Office, the medical certificate issued by Dr. Soriano, and the psychiatric evaluation and testimony of Dela Cruz.

“Obviously, Irene raises factual issues, which this Court finds no reason to review. For one, the lower courts' factual findings are the same. It is true that the Court of Appeals heavily lifted portions of the Regional Trial Court Decision in making its findings, but this only means that it agreed with the trial court's findings.

“Also, the finding that Alfredo suffered from schizophrenia is sufficiently supported by evidence. Even if we disregard the purportedly unauthenticated documents issued by the United States Veteran Affairs Office and Dr. Soriano, we find that Dela Cruz's expert testimony sufficiently proved that Alfredo suffered from schizophrenia.

“Irene herself, on re-cross examination during trial, admitted that she receives pension from the Veterans Affairs Office because of Alfredo' s schizophrenia. Given that Alfredo's disorder was sufficiently established, this Court has no reason to review, much less overturn, this factual finding.

“Finally, we find no evidence of extrinsic fraud to warrant Irene a new trial of the case.

“Here, there is no evidence that Alfredo committed fraud to prevent Irene from fully exhibiting her case in court. Neither was there any evidence of a false promise or compromise.

“On the contrary, Irene was fully informed of the trial proceedings, including the filing of the Complaint for declaration of nullity of marriage. When Irene initially had no means to avail herself of legal services, the trial court allowed her to file a belated Answer with the assistance of the Public Attorney's Office.

“With no evidence of the fraud she alleges, Irene's Motion for New Trial was correctly denied.

“WHEREFORE, the Petition for Review on Certiorari is DENIED. The September 28, 2012 Decision and September 18, 2013 Resolution of the Court of Appeals in CA-G.R. CV No. 93166 are AFFIRMED. SO ORDERED.”