REPUBLIC OF THE PHILIPPINES, PETITIONER, V. MARTIN NIKOLAI Z. JAVIER AND MICHELLE K.

MERCADO-
JAVIER, RESPONDENTS.

2018-04-18 | G.R. No. 210518

DECISION Void Marriages – Psychological Incapacity

REYES, JR., J: Petition for review on certiorari

Facts:

Martin alleged that both he and Michelle were psychologically incapacitated to comply with the
essential obligations of marriage. He thus prayed for the declaration of nullity of their marriage, and for
the joint custody of their minor child, Amanda M. Javier. Dr. Adamos concluded in the Psychological
Evaluation Report that both Martin and his wife Michelle suffered from the same Narcissistic Personality
Disorder. Their disorder was considered grave and incurable, and rendered Martin and Michelle
incapacitated to perform the essential obligations of marriage.

However, Dr. Adamos was unable to evaluate Michelle. The basis of Dr. Adamos' findings on the
psychological incapacity of Michelle was the information provided by Martin and Jose Vicente, a close
friend of both of them. On this ground, the RTC denied the petition finding Martin's testimony to be self-
serving and Dr. Adamos' findings to be without sufficient basis. The CA reversed the decision and found
that there were sufficient evidence to support Martin's claim that he is psychologically incapacitated.
However, it also negated the RTC's ruling by referring to Martin's own testimony, in which he narrated
his tendency to impose his own unrealistic standards on Michelle

The Republic petition for review arguing that the testimony of Martin was self-serving, especially in
relation to Dr. Adamos' diagnosis.

Issues:

Controlling:

(1) Whether or not the testimony of Martin in relation to Dr. Adamos’ diagnosis is admissible
(2) Whether or not Michelle is psychologically incapacitated
(3) Whether or not Martin is psychologically incapacitated

General: Whether or not the Court of Appeals erred in declaring the marriage of the respondents null
and void under Article 36 of the Family Code.

Ruling:

(1) Yes. While it is true that Michelle was not personally examined, the trial court was incorrect in
invalidating the marriage for this reason alone. Since a marriage necessarily involves only two
persons, the spouse who witnessed the other spouse's behavior may "validly relay" the pattern
of behavior to the psychologist.
(2) No. Dr. Albos has no credible source of Michelle’s supposed childhood trauma since records do
not show that Michelle and Jose Vicente were childhood friends, while Martin, on the other
hand, was introduced to Michelle during their adulthood. Now since they, as third persons
outside the family of Michelle, could not have known about her childhood, how she was raised,
 and the dysfunctional nature of her family --therefore, Dr. Adamos was not equipped with
enough information from which he may reasonably conclude that Michelle is suffering from a
chronic and persistent disorder that is grave and incurable.

(3) Yes. The totality of evidence supports the finding that Martin is psychologically incapacitated to
perform the essential obligations of marriage.

Dr. Adamos concluded from the tests administered on Martin that this disorder was rooted in the
traumatic experiences he experienced during his childhood, having grown up around a violent father
who was abusive of his mother. This adversely affected Martin in such a manner that he formed
unrealistic values and standards on his own marriage, and proposed unconventional sexual practices.
When Michelle would disagree with his ideals, Martin would not only quarrel with Michelle, but would
also inflict harm on her. Other manifestations include excessive love for himself, self-entitlement,
immaturity, and self-centeredness. These circumstances, taken together, prove the three essential
characteristics of psychological incapacity (gravity; juridical antecedence; and incurability) on the part of
Martin.

No. As such, insofar as the psychological incapacity of Martin is concerned, the CA did not commit a
reversible error in declaring the marriage of the respondents null and void under Article 36 of the Family
Code.

WHEREFORE, premises considered, the petition for review on certiorari is PARTIALLY GRANTED insofar
as the psychological incapacity of respondent Michelle K. Mercado-Javier is concerned. The Decision
dated July 10, 2013 and Resolution dated November 28, 2013 of the Court of Appeals in CA-G.R. CV No.
98015 are MODIFIED to the extent that the marriage of the respondents on February 8, 2002 is declared
NULL and VOID AB INITIO due to the psychological incapacity of respondent Martin Nikolai Z. Javier,
pursuant to Article 36 of the Family Code.

As a final note, the Court emphasizes that the factual circumstances obtaining in this specific case
warrant the declaration that Martin is psychologically incapacitated to perform the essential marital
obligations at the time of his marriage to Michelle. This is neither a relaxation nor abandonment of
previous doctrines relating to Article 36 of the Family Code. The guidelines in Molina still apply to all
petitions for declaration of nullity of marriage inasmuch as this Court does not lose sight of the
constitutional protection to the institution of marriage.