Case Digest: Tan-Andal vs. Andal
Rosanna L. Tan-Andal vs. Mario Victor M. Andal
G.R. No. 196359 • May 11, 2021
Leonen, J.
Facts
- Mario and Rosanna married in 1995. In 1996, Rosanna gave birth to Ma. Samantha. As the family cohabited, Mario showed signs of emotional immaturity, financial irresponsibility, and drug abuse.
- In 2000, the separated and Rosanna kept custody of Ma. Samantha. In 2001, Mario filed a petition for equal custody of Ma. Samantha before the Regional Trial Court. In 2003, Rosanna filed a petition for declaration of nullity of their marriage due to psychological incapacity. The two cases were consolidated in 2004.
- Dr. Valentina Del Fonso Garcia became a witness on Mario’s psychological incapacity, interviewing Rosanna, Ma. Samantha, and Rosanna’s sister Jocelyn. Dr. Garcia diagnosed him with narcissistic antisocial personality disorder and substance abuse disorder with psychotic features.
- In 2007, the RTC granted Rosanna’s petition, declaring their marriage void ab initio and awarding absolute custody to Ma. Samantha and absolute ownership of their properties.
- In 2010, the Court of Appeals reversed the decision, citing that the psychiatric evaluation of Mario was deemed unscientific and unreliable by not interviewing him.
Issue/s
- Whether Mario and Rosanna’s marriage is null and void ab initio due to psychological incapacity.
- Whether the current guidelines for nullity of marriage due to psychological incapacity under the Molina decision violate human rights and is valid.
- Whether psychological incapacity may be relative to each couple.
Ruling/Held
Rosanna’s petition is GRANTED, the 2010 CA decision is REVERSED, the 2007 RTC decision is REINSTATED.
Ratio
- Mario is psychologically incapacitated to fulfill his essential marital obligations. – While abandoning the requirement, the Court ruled that Dr. Garcia’s psychological evaluation is valid as an expert opinion in proving Mario’s psychological incapacity, using not just collateral information but also his handwritten personal history. His drug abuse, while a ground for legal separation, is also a manifestation of his psychological incapacity.
- The Molina guidelines are rigid and “inconsistent with the way the concept was formulated”. The Court revisits the guidelines. —
- The plaintiff-spouse must prove their case with clear and convincing evidence: more than preponderant evidence in civil cases but less than proof beyond reasonable doubt in criminal cases.
- Psychological incapacity is a not a medical term or personality disorder and is limited to psychic causes, therefore, the requirement of expert opinion is abandoned.
- Juridical antecedence is upheld by the Court, meaning that psychological incapacity must be existing before the celebration of the marriage, even if incapacity manifests after it.
- Incurability is a legal term, not a medical term. It refers to the incompatibility of the couple that leads to inevitable breakdown of the marriage. Therefore, it does not prohibit the psychologically incapacitated spouse to remarry, “as it would only result in another void marriage.”
- Marital obligations are not limited to obligations as husband and wife, but also as parents to their children.
- The persuation of the Catholic Church is upheld.
Read the entirety of the Supreme Court decision here: https://lawphil.net/judjuris/juri2021/may2021/gr_196359_2021.html