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G.R. No. 196359. May 11, 2021 (Case Brief - Digest)

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24 views2 pages

G.R. No. 196359. May 11, 2021 (Case Brief - Digest)

Uploaded by

Christine Marie
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No. 196359.

May 11, 2021 (Case Brief / Digest)

Title: Rosanna L. Tan-Andal v. Mario Victor M. Andal: A Case of Void Marriage Due to
Psychological Incapacity

Facts: Mario Victor M. Andal and Rosanna L. Tan were married on December 16, 1995. They
had a daughter, Ma. Samantha, but after four years of marriage, the couple separated in
2000 due to Mario’s alleged psychological incapacity. Post-separation, Rosanna maintained
sole custody of their child. Mario initially filed for custody, arguing equal rights over Ma.
Samantha, while Rosanna filed for the declaration of nullity of marriage, attributing Mario’s
psychological incapacity as the cause.

During their marriage, Mario displayed behavior suggestive of psychological issues, such as
unaccounted absences, financial irresponsibility, drug use, and instances suggesting
paranoia. Post-maternity, Mario’s behavior worsened; he did not support Rosanna nor their
daughter and engaged in drug use that led to negligence and paranoid behavior. When these
problems persisted, Rosanna eventually petitioned the Regional Trial Court to commit Mario
to a drug rehabilitation center.

Rosanna presented Dr. Valentina Del Fonso Garcia as an expert witness, who diagnosed
Mario with a narcissistic antisocial personality disorder and substance abuse disorder with
psychotic features. These disorders prevented Mario from fulfilling his marital and parental
responsibilities. Despite these findings, the Court of Appeals reversed the trial court’s
decision to void the marriage.

Issues:
1. Whether Mario’s marriage to Rosanna is void due to psychological incapacity.
2. Whether the property acquired during their union should be considered communal.
3. Whether the custody of Ma. Samantha was rightfully awarded to Rosanna.

Court’s Decision:
The Court grants the Petition for Review on Certiorari, finding that clear and convincing
evidence supports Rosanna’s claim of Mario’s psychological incapacity. The Supreme Court
holds that psychological incapacity is not limited to medically diagnosed mental disorders but
includes character traits that prevent compliance with essential marital obligations. Property
relations are governed by Article 147, where only properties jointly acquired through the
efforts of the spouses are considered common. In this case, it was proven that Rosanna and
her father funded the construction of the family home, and Rosanna received the contested
property through donation, making Mario ineligible for a share in the property. Custody of

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G.R. No. 196359. May 11, 2021 (Case Brief / Digest)

Ma. Samantha is rightfully awarded to Rosanna, as she consistently demonstrated care and
support for the child during their separation.

Doctrine:
1. Psychological incapacity under Article 36 of the Family Code does not require medical or
clinical identification but encompasses clear acts of dysfunctionality in personality that
hinder the fulfillment of marital obligations.
2. Property relations between parties in a void marriage are governed by the rules of co-
ownership in proportion to actual contributions unless proven solely attributable to one party.
3. In child custody matters post parental separation, the primary consideration is the child’s
best interest, which typically aligns with awarding custody to the parent who has shown
continuous support and care.

Historical Background:
The concept of psychological incapacity in Philippine law has undergone an evolution since
the seminal cases of Santos v. Court of Appeals and Molina. The Supreme Court’s
interpretation has transitioned from a stringent application of guidelines to a more nuanced
understanding that respects individual rights and aligns with the evolution of psychological
science. The case at hand signifies a significant shift away from requiring medical diagnoses
and towards recognizing the complex nature of human relationships and their effects on
family and marriage.

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