In the recent case of Te v. Yu-Te and the Republic of the Philippines, this Court reiterated that courts should interpret the provision on psychological incapacity (as a ground for the declaration of nullity of a marriage) on a case-to-case basis — guided by experience, the findings of experts and researchers in psychological disciplines and by decisions of church tribunals.
Accordingly, we emphasized that, by the very nature of Article 36, courts, despite having the primary task and burden of decision-making, must consider as essential the expert opinion on the psychological and mental disposition of the parties.
Ultimately, Dr. Dayan concluded that petitioner’s personality disorder was grave and incurable and already existent at the time of the celebration of his marriage to respondent.
It has been sufficiently established that petitioner had a psychological condition that was grave and incurable and had a deeply rooted cause. This Court, in the same Te case, recognized that individuals with diagnosable personality disorders usually have long-term concerns, and thus therapy may be long-term. Particularly, personality disorders are “long-standing, inflexible ways of behaving that are not so much severe mental disorders as dysfunctional styles of living. These disorders affect all areas of functioning and, beginning in childhood or adolescence, create problems for those who display them and for others.”
From the foregoing, it has been shown that petitioner is indeed suffering from psychological incapacity that effectively renders him unable to perform the essential obligations of marriage. Accordingly, the marriage between petitioner and respondent is declared null and void.