PERSONS - VILLANON v. VILLANON G.R. No. 167206

Reynaldo, Hark Emmanuelle Joaquin B.
1D Persons and Family
JAIME F. VILLALON, petitioner v. MA.CORAZON N. VILLALON, respondent

G.R. No. 167206 November 18, 2005
Psychological incapacity, as a ground for the declaration of nullity of a marriage, must be

characterized by juridical antecedence, gravity and incurability
Facts: Petitioner testified that he met respondent sometime in the early seventies when he
applied for a job at Metrobank, where respondent was employed as a foreign exchange trader.
After going steady for about two years, petitioner and respondent were married on April 22,
1978. Petitioner claimed that he married respondent because he believed that it was the right
time to raise a family and that she would be a good mother to his children. In the middle of
1993, petitioner decided to separate from respondent. According to him, their marriage
reached a point where there was no longer any communication between them and their
relationship became devoid of love, affection, support and respect due to his constant urge to
see other women. In January 1994, petitioner left the conjugal abode and moved into an
apartment located five to ten minutes away. Before he left, he and his wife spoke to their three
children who, at that time, were 14, 8, and 6 years old, respectively. Petitioner consulted a child
psychologist before talking to his children. He considered himself as a good and loving father
and described his relationship with the children as 'great. Despite the separation, petitioner
would regularly visit his children who stayed with him on alternate weekends. He voluntarily
gave monthly support to the children and paid for their tuition fees.
Petitioner presented Dr. Natividad Dayan, a clinical psychologist, to testify on his alleged
psychological disorder of 'Narcissistic Histrionic Personality Disorder with 'Casanova Complex.
Dr. Dayan described the said disorder as 'a pervasive maladaptation in terms of interpersonal
and occupational functioning with main symptoms of grand ideation about oneself, self-
centeredness, thinking he is unique and wanting to always be the one followed, the I
personality.
To controvert the findings of petitioner's expert witness, respondent presented a psychiatrist,
Dr. Cecilia Villegas, who testified that Dr. Dayan's findings were incomplete because a team
approach was necessary in evaluating an individual's personality. An evaluation of one's
psychological capacity requires the expertise of a psychiatrist and social worker.
The Regional Trial Court granted the petition and declared their marriage void ad initio due to
psychological incapacity.
The Court of Appeals reversed and set aside the decision of the trial court. They held that that
petitioner failed to prove the juridical antecedence, gravity and incurability of his alleged
psychological incapacity. Dr. Dayan also stated that parental marital instability was the root
cause of petitioner's psychological incapacity but failed to elaborate thereon or link the two
variables.
Issues: Whether or not the marriage between Jaime and Ma. Corazon be void on the ground of
psychological incapacity
Held: No. The totality of the evidence in this case does not support a finding that petitioner is
psychologically incapacitated to fulfill his marital obligations. On the contrary, what is evident is
the fact that petitioner was a good husband to respondent for a substantial period of time prior
to their separation, a loving father to their children and a good provider of the family. Although
he engaged in marital infidelity in at least two occasions, the same does not appear to be
symptomatic of a grave psychological disorder which rendered him incapable of performing his
spousal obligations. The same appears as the result of a general dissatisfaction with his
marriage rather than a psychological disorder rooted in petitioner's personal history.
In Santos v. Court of Appeals, the court held that psychological incapacity, as a ground for the
declaration of nullity of a marriage, must be characterized by juridical antecedence, gravity and
incurability. In the case at bar, although Dr. Dayan testified that petitioner suffered from
Narcissistic Histrionic Personality Disorder with Casanova Complex even before the marriage
and thus had the tendency to cheat on his wife, such conclusion was not sufficiently backed by
concrete evidence showing that petitioner indeed had several affairs and finds it difficult to be
faithful.
Moreover, the court is not convinced that petitioner is a 'serial or habitual adulterer', as he
wants the court to believe. As stated by respondent herself, it cannot be said that two instances
of infidelity which occurred 13 years apart could be deemed 'womanizing', especially
considering that these instances involved the same woman. In fact, at the time of respondent's
testimony, petitioner's illicit relationship has been going on for six years. This is not consistent
with the symptoms of a person suffering from 'Casanova Complex
In the instant case, it appears that petitioner has simply lost his love for respondent and has
consequently refused to stay married to her. As revealed by his own testimony, petitioner felt
that he was no longer part of respondent's life and that the latter did not need or want him.
[37] Respondent's uncommunicative and withdrawn nature apparently led to petitioner's
discontentment with the marital relationship.
However, as held in Rep. of the Phils. v. Court of Appeals, refusal to comply with the essential
obligations of marriage is not psychological incapacity within the meaning of the law. The policy
of the State is to protect and strengthen the family as the basic social institution and marriage is
the foundation of the family. Thus, any doubt should be resolved in favor of validity of the
marriage.

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Reynaldo, Hark Emmanuelle Joaquin B.

1D Persons and Family

JAIME F. VILLALON, petitioner v. MA.CORAZON N. VILLALON, respondent

Psychological incapacity, as a ground for the declaration of nullity of a marriage, must be

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