The Supreme Court ruled that the marriage between Constancia Javate-Asejo and Justiniano Zantua Asejo is null and void due to Justiniano’s psychological incapacity. This decision emphasizes that a spouse’s persistent irresponsibility and dependence can constitute psychological incapacity if proven to be grave, antecedent, and incurable. The court underscored that such incapacity goes beyond simple immaturity, reflecting a profound inability to fulfill essential marital obligations.

When ‘Irresponsibility’ Masks Incapacity: Unraveling the Asejo Marriage

Constancia Javate-Asejo petitioned for the nullification of her marriage to Justiniano Zantua Asejo based on Article 36 of the Family Code, asserting Justiniano’s psychological incapacity. The Regional Trial Court (RTC) initially granted the petition, but the Court of Appeals (CA) reversed this decision, leading Constancia to elevate the case to the Supreme Court. The central legal question was whether Justiniano’s behavior, characterized by habitual drunkenness, gambling, and a refusal to seek employment, amounted to psychological incapacity that rendered him incapable of fulfilling the essential obligations of marriage.

The Supreme Court, in resolving the issue, analyzed the totality of the evidence presented, including the testimony of expert witness Dr. Ethel Maureen Biscarro Pagaddu. The Court emphasized the importance of considering the gravity, juridical antecedence, and incurability of the alleged psychological incapacity. It noted that Dr. Pagaddu’s assessment, based on interviews with Constancia, Justiniano’s sister, and sister-in-law, sufficiently traced and explained the root cause of Justiniano’s personality disorder and its impact on his relationship with Constancia. The Court contrasted this case with Rumbaua v. Rumbaua, where the expert’s conclusions were based solely on information from one party.

The Supreme Court placed significant weight on Dr. Pagaddu’s finding that Justiniano’s condition stemmed from his upbringing within a dysfunctional family environment, where his parents fostered dependence and shielded him from experiencing frustrations. This pattern, according to the expert, led to a self-centered, impulsive, and irresponsible disposition, severely affecting his ability to function as a responsible husband and father. The High Tribunal cited the RTC’s observation that Justiniano’s psychological disorder was chronic and ingrained in his personality, originating from negative factors during his formative years.

The Court highlighted that the law does not mandate a personal examination by a physician or psychologist to declare someone psychologically incapacitated. It asserted that independent proof of a psychological disorder is sufficient. The Justices noted that Dr. Pagaddu’s conclusions were not merely based on Constancia’s statements but were corroborated by interviews with Justiniano’s close relatives. This triangulation of data strengthened the validity of the expert’s findings, reinforcing the assertion of Justiniano’s profound inability to grasp and fulfill marital responsibilities.

In its analysis, the Supreme Court addressed the CA’s contention that Justiniano’s behavior, such as habitual drunkenness and refusal to seek employment, did not by themselves constitute psychological incapacity. The Court clarified that while these behaviors are not determinative on their own, they are indicative of a deeper underlying psychological issue when viewed in the context of the expert’s findings and other evidence presented. The justices emphasized that such behaviors, coupled with Justiniano’s pathologic over-reliance on others, demonstrated a profound lack of understanding regarding his personal responsibility for the support and well-being of his family.

The Supreme Court drew a parallel to Azcueta v. Republic of the Philippines, where the husband’s dependent personality disorder was deemed sufficient to establish psychological incapacity. The High Tribunal reiterated that the family should be an autonomous social institution where spouses cooperate and are equally responsible for the family’s support and well-being. The Supreme Court noted that Justiniano’s dependency prevented him from embracing autonomy and affording the same to his wife and family. The court emphasized that a spouse’s failure to fulfill essential marital obligations due to a persisting psychological malady cannot be excused.

Furthermore, the Court noted that even the evidence presented by the OSG (Office of the Solicitor General) supported the conclusion that Justiniano was psychologically incapacitated. The OSG’s comment acknowledged that Constancia’s parents were disappointed by Justiniano’s unemployment and lack of means to support a family. The Justices observed how even Justiniano’s relatives carried the burden for basic necessities such as childbirth expenses.

The Supreme Court ultimately found that Constancia presented clear and convincing evidence of Justiniano’s psychological incapacity, meeting the standard of proof articulated in Tan-Andal v. Andal. This evidence included expert testimony, corroborating witness statements, and admissions from the OSG. The Court concluded that Justiniano’s condition, characterized by gravity, antecedence, and incurability, prevented him from recognizing his essential marital obligations, rendering his marriage to Constancia null and void ab initio. This ruling serves as a reminder that psychological incapacity is not merely about incompatibility but a deep-seated inability to understand and fulfill the fundamental duties of marriage.

FAQs

What was the key issue in this case?	The key issue was whether Justiniano’s habitual irresponsibility and dependence constituted psychological incapacity under Article 36 of the Family Code, justifying the nullification of his marriage to Constancia. The Supreme Court sought to determine if Justiniano’s behavior stemmed from a genuine psychological disorder that rendered him incapable of fulfilling his marital obligations.
What is psychological incapacity under Philippine law?	Psychological incapacity, as defined in Article 36 of the Family Code, refers to a mental condition that renders a person unable to understand and fulfill the essential obligations of marriage. This condition must be grave, antecedent (existing at the time of the marriage), and incurable.
What evidence did Constancia present to prove Justiniano’s psychological incapacity?	Constancia presented the expert testimony of Dr. Ethel Maureen Biscarro Pagaddu, who interviewed Constancia, Justiniano’s sister, and sister-in-law. She also presented witness testimonies from close friends and neighbors, detailing Justiniano’s behavior and its impact on their marriage.
Why was the expert’s testimony considered credible in this case?	The expert’s testimony was deemed credible because it was based on interviews with multiple sources, including Justiniano’s relatives. The expert’s conclusions were not solely based on Constancia’s account, mitigating concerns about bias and ensuring a more comprehensive assessment.
Did the Supreme Court require a personal examination of Justiniano by the expert?	No, the Supreme Court clarified that a personal examination by a physician or psychologist is not a strict requirement for establishing psychological incapacity. Independent proof of a psychological disorder, gathered through other means, is sufficient.
What was the significance of Justiniano’s refusal to seek employment?	Justiniano’s persistent refusal to seek employment was viewed as a manifestation of his underlying psychological incapacity. This behavior, coupled with his over-reliance on others and lack of concern for his family’s well-being, indicated a deep-seated inability to fulfill his marital obligations.
How did the Supreme Court distinguish this case from Rumbaua v. Rumbaua?	In Rumbaua, the expert’s conclusions were based solely on information from one party, the petitioner. In contrast, Dr. Pagaddu interviewed multiple sources, including Justiniano’s relatives, providing a more balanced and reliable assessment.
What is the standard of proof required in nullity cases under Article 36?	The standard of proof required in nullity cases under Article 36 is clear and convincing evidence, as established in Tan-Andal v. Andal. This standard requires a higher degree of certainty than preponderance of evidence, demanding a more compelling and persuasive demonstration of psychological incapacity.
What is the impact of this decision on future cases of psychological incapacity?	This decision underscores that persistent irresponsibility and dependence can constitute psychological incapacity if proven to be grave, antecedent, and incurable. It clarifies that courts should consider the totality of evidence, including expert testimony and witness statements, to determine whether a spouse is genuinely incapable of fulfilling marital obligations.

The Supreme Court’s decision in Javate-Asejo v. Asejo refines the understanding of psychological incapacity within Philippine family law. This case reinforces that psychological incapacity must be deeply rooted and render a spouse incapable of understanding and performing their essential marital duties. The Court emphasized the need to consider the unique circumstances of each case, balancing the preservation of marriage with the need to protect individuals from unsustainable unions.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Constancia Javate-Asejo v. Justiniano Zantua Asejo, G.R. No. 247798, January 18, 2023