TANI-DE LA FUENTE vs. DE LA FUENTE

TANI-DE LA FUENTE vs. DE LA FUENTE

G.R. No. 188400, March 8, 2017

SECOND DIVISION

Leonen, J.

Psychological Incapacity

PETITION FOR REVIEW assailing the Decision and Resolution of Court of Appeals (CA) which reversed the Decision of the Regional Trial Court (RTC).

Facts:

Petitioner Maria Teresa Tani-De La Fuente and Rodolfo De La Fuente’s relationship started when they were students in the University of Santo Tomas. They married on June 21, 1984.

Maria Teresa observed that even before marriage Rodolfo was introvert and prone to jealousy. He had no ambitions and was insecure of his siblings who excelled in their studies and careers. Rodolfo’s attitude worsened as they went on their marital life. Rodolfo’s jealousy was so severe that he pointed a gun at a 15 year-old cousin staying at their home whom he suspected to be Maria Teresa’s lover. In addition, Rodolfo treated Maria Teresa as a sex slave, having sex 4-5 times a day, even fetching Maria Teresa on lunch breaks just so they could have sex. Rodolfo has even suggested that they even invite a third person into their bed, or another man to have sex with Maria Teresa while Rodolfo watches. 

In 1986, at the heat of a quarrel, Rodolfo poked a gun at Maria Teresa. That prompted Maria Teresa to leave the conjugal dwelling, and from then on never saw Rodolfo again, and she supported the children by herself.

On June 3, 1999, Maria Teresa filed a petition for declaration of nullity of marriage. It was initially archived for Rodolfo’s failure to file a responsive pleading but it was subsequently revived. The Assistant City Prosecutor found no collusion between the parties. Rodolfo failed to attend the pre-trial conference and Maria Teresa was allowed to present evidence ex parte.

Dr. Arnulfo V. Lopez (Dr. Lopez), a clinical psychologist, was presented as an expert witness. Dr. Lopez testified that he conducted an in-depth interview with Maria Teresa to gather information on her family background and her marital life with Rodolfo, and subjected her to a battery of psychological tests. Dr. Lopez also interviewed Rodolfo's best friend.

After subjecting Maria Teresa to interviews and tests, Dr. Lopez concluded that Maria Teresa was not suffering from any severe mental disorder and had no indication of any organic or functional impairment. Dr. Lopez diagnosed Rodolfo with "paranoid personality disorder manifested by [Rodolfo's] damaging behavior like reckless driving and extreme jealousy; his being distrustful and suspicious; his severe doubts and distrust of friends and relatives of [Maria Teresa]; his being irresponsible and lack of remorse; his resistance to treatment; and his emotional coldness and severe immaturity." Lopez explained that Rodolfo's personality disorder was most probably caused by a pathogenic parental model. Rodolfo's family background showed that his father was a psychiatric patient, and Rodolfo might have developed psychic contamination called double insanity, a symptom similar to his father's. Dr. Lopez further claimed that Rodolfo's disorder was serious and incurable because of his severe paranoia.

The RTC granted the petition but the CA reversed the RTC finding the testimony of Dr. Lopez unreliable for being hearsay. The CA disagreed with Dr. Lopez's finding that Rodolfo's behavior descended from psychological illness contemplated under Article 36 of the Family Code.

Issue:

Whether or not the petitioner's evidence was insufficient to prove that Rodolfo was psychologically incapacitated to fulfill his marital obligation.

Ruling: 

Yes. GRANTED.

By the very nature of Article 36, courts, despite having the ultimate task of decision-making, must give due regard to expert opinion on the psychological and mental disposition of the parties.

The root cause of respondent's paranoid personality disorder was hereditary in nature as his own father suffered from a similar disorder. Dr. Lopez stated that respondent's own psychological disorder probably started during his late childhood years and developed in his early adolescent years. Dr. Lopez explained that respondent's psychological incapacity to perform his marital obligations was likely caused by growing up with a pathogenic parental model.

The juridical antecedence of respondent's psychological incapacity was also sufficiently proven during trial. Petitioner attested that she noticed respondent's jealousy even before their marriage, and that he would often follow her to make sure that she did not talk to anyone or cheat on him. She believed that he would change after they got married; however, this did not happen. Respondent's jealousy and paranoia were so extreme and severe that these caused him to poke a gun at petitioner's head.

The incurability and severity of respondent's psychological incapacity were likewise discussed by Dr. Lopez. He vouched that a person with paranoid personality disorder would refuse to admit that there was something wrong and that there was a need for treatment. This was corroborated by petitioner when she stated that respondent repeatedly refused treatment. Petitioner consulted a lawyer, a priest, and a doctor, and suggested couples counselling to respondent; however, respondent refused all of her attempts at seeking professional help. Respondent also refused to be examined by Dr. Lopez.

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Respondent's repeated behavior of psychological abuse by intimidating, stalking, and isolating his wife from her family and friends, as well as his increasing acts of physical violence, are proof of his depravity, and utter lack of comprehension of what marriage and partnership entail. It would be of utmost cruelty for this Court to decree that petitioner should remain married to respondent. After she had exerted efforts to save their marriage and their family, respondent simply refused to believe that there was anything wrong in their marriage. This shows that respondent truly could not comprehend and perform his marital obligations. This fact is persuasive enough for this Court to believe that respondent's mental illness is incurable.