The Supreme Court has clarified the application of Article 36 of the Family Code regarding psychological incapacity as a ground for nullifying marriages celebrated before the Code’s enactment. While affirming the retroactive applicability of Article 36 to such marriages, the Court emphasized the stringent requirements for proving psychological incapacity, particularly in light of the Tan-Andal v. Andal ruling. Ultimately, the Court upheld the validity of the marriage, finding that the evidence presented failed to sufficiently establish the gravity, incurability, and juridical antecedence of the petitioner’s alleged psychological incapacity. This decision underscores the judiciary’s commitment to protecting the institution of marriage while also recognizing legitimate claims of psychological incapacity that render a party unable to fulfill essential marital obligations.

When Does ‘I Do’ Really Mean ‘I Can’t?’: Examining Psychological Incapacity Before the Family Code

Arthur A. Candelario sought to nullify his marriage to Marlene E. Candelario, which occurred on June 11, 1984, prior to the effectivity of the Family Code on August 3, 1988. Arthur argued that his Dependent Personality Disorder constituted psychological incapacity, rendering him unable to comply with essential marital obligations. The Regional Trial Court (RTC) initially denied the petition, reasoning that the Family Code could not be applied retroactively. However, the Supreme Court disagreed with the RTC’s initial conclusion on retroactivity, clarifying that Article 36 of the Family Code, concerning psychological incapacity, can indeed be applied retroactively to marriages celebrated before the Code’s effectivity, provided that no vested or acquired rights are prejudiced. This opened the door for re-evaluation of Arthur’s claim under the standards set by the Family Code.

The core of the legal discussion centered on the interpretation and application of Articles 36, 39, and 256 of the Family Code. Article 36 defines psychological incapacity as a ground for nullity, even if the incapacity manifests after the marriage. Article 39 addresses the prescription of actions for nullity, now stating that such actions do not prescribe, regardless of when the marriage was solemnized. Article 256 provides for the retroactive effect of the Family Code, as long as it does not prejudice vested or acquired rights. The Supreme Court emphasized that the absence of a distinction in the law implies that courts should not create one. This principle of statutory construction supports the retroactive application of Article 36.

Art. 36. A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization.

Furthermore, the Court referenced Santos v. Court of Appeals, highlighting the Family Code Revision Committee’s deliberations on psychological incapacity, including explicit consideration of its retroactive application. This historical context reinforces the intent to address situations where individuals were genuinely incapable of fulfilling marital obligations, regardless of the marriage date. The court acknowledged numerous prior cases where Article 36 had been applied to marriages predating the Family Code. This consistent application demonstrates a pattern of judicial recognition for the retroactive effect of the law.

Despite affirming the potential for retroactive application, the Supreme Court ultimately upheld the RTC’s decision to deny Arthur’s petition. This was based on a failure to meet the stringent evidentiary requirements for proving psychological incapacity, as clarified in Tan-Andal v. Andal. Tan-Andal shifted the focus from reliance on expert psychiatric testimony to a more holistic assessment of the individual’s personality structure and its impact on marital obligations. The court emphasized that psychological incapacity must be grave, incurable, and juridically antecedent, meaning it must exist before the marriage.

In evaluating Arthur’s case, the Court found that the psychiatric report presented lacked sufficient evidence to establish these critical elements. The report, while identifying a Dependent Personality Disorder, failed to demonstrate how this condition specifically incapacitated Arthur from fulfilling his marital duties. There was no clear evidence that his condition made it practically impossible for him to comply with the ordinary duties required in marriage, and his behavior could be attributed to mere refusal, neglect, difficulty, or ill will, rather than a genuine incapacity. The Court found that the requirement of gravity was not satisfied.

The Court further noted that the requirement of incurability was not sufficiently proven. While Arthur had an extramarital affair, there was insufficient evidence to demonstrate that his condition was incurable. The psychiatric report offered only a general evaluation, stating that the condition was unlikely to respond to treatment, without providing concrete evidence to support this conclusion. The report lacked specific details about his personality structure that would point to a persisting failure in being a loving, faithful, respectful, and supportive spouse. Finally, the Court found that the requirement of juridical antecedence was not met because corroborating testimony failed to establish that Arthur’s condition existed prior to his marriage to Marlene.

Ultimately, the Supreme Court’s decision reinforces the principle that an unsatisfactory marriage is not necessarily a null and void marriage. The stringent requirements for proving psychological incapacity are designed to protect the sanctity of marriage, ensuring that only genuine cases of incapacity, as defined by Article 36 of the Family Code and clarified by jurisprudence, warrant the dissolution of marital bonds. This case highlights the delicate balance between upholding the institution of marriage and recognizing the rights of individuals who are truly incapable of fulfilling its essential obligations.

FAQs

What was the key issue in this case?	The central issue was whether Article 36 of the Family Code, concerning psychological incapacity, could be applied retroactively to marriages celebrated before the Code’s effectivity. The Court ruled that it could, but the petitioner failed to prove psychological incapacity.
What is psychological incapacity under the Family Code?	Psychological incapacity refers to a party’s inability to understand and comply with the essential marital obligations, such as living together, mutual love, respect, and fidelity, due to a grave, incurable, and pre-existing condition. It’s not simply a matter of unwillingness or difficulty in fulfilling these obligations.
Did the Court declare the marriage void in this case?	No, the Supreme Court affirmed the lower court’s decision, which upheld the validity of the marriage between Arthur and Marlene Candelario. The Court found that Arthur failed to provide sufficient evidence of psychological incapacity.
What is the significance of the Tan-Andal v. Andal case?	Tan-Andal v. Andal changed the way psychological incapacity is evaluated. The Court shifted the focus from expert psychiatric testimony to a more holistic assessment of the individual’s personality structure and its impact on fulfilling marital obligations.
What evidence is required to prove psychological incapacity?	Clear and convincing evidence is required to prove that the incapacity is grave, incurable, and existed prior to the marriage. This includes showing how the individual’s personality structure makes it impossible for them to understand and comply with essential marital obligations.
What does it mean for a psychological incapacity to be ‘juridically antecedent’?	‘Juridically antecedent’ means that the psychological incapacity must have existed at the time of the marriage celebration, even if it only became manifest afterward. Evidence must show that the condition was present before the marriage.
Can a marriage be declared void simply because the spouses have irreconcilable differences?	No, irreconcilable differences, conflicting personalities, emotional immaturity, and other similar factors are not sufficient grounds for declaring a marriage void based on psychological incapacity. The incapacity must be grave and prevent the party from fulfilling essential marital obligations.
What happens if a spouse refuses to present evidence in a nullity case?	If a spouse fails to present evidence despite being given the opportunity, they are deemed to have waived their right to prove and testify on matters relevant to the case. The court will then decide based on the evidence presented by the other party.

In conclusion, the Supreme Court’s decision in Candelario v. Candelario clarifies the retroactive application of Article 36 of the Family Code while reinforcing the stringent requirements for proving psychological incapacity. The case underscores the judiciary’s commitment to balancing the sanctity of marriage with the recognition of genuine cases of psychological incapacity that prevent individuals from fulfilling essential marital obligations.

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: Candelario v. Candelario, G.R. No. 222068, July 25, 2023