327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a marriage be declared void ab initio based on both
parties’ psychological incapacity, as diagnosed post-marriage, even without
direct psychiatric examination of one of the spouses?
Republic of the Philippines vs. Angelique Pearl O. Claur
and Mark A. Claur
G.R. No. 246868, February 15, 2022
Facts of the Case:
Angelique Pearl O. Claur petitioned to have her marriage to
Mark A. Claur declared null and void on the grounds of both parties'
psychological incapacity. Their relationship began in high school and was
marked by jealousy, emotional manipulation, and frequent breakups. Despite
these issues, the couple married in 2009 after Angelique became pregnant.
However, their marriage continued to deteriorate, marked by constant fighting,
physical abuse, and mutual disrespect.
Angelique described Mark as lazy, extravagant, and prone to
vices. He lied about his education and family background, leaving Angelique as
the primary financial provider. Mark physically assaulted Angelique, breaking
her jaw during one fight. Despite these incidents, Mark refused to seek
employment and remained dependent on Angelique for financial support. After
years of on-and-off separation, they finally parted ways in 2012.
Angelique was diagnosed with borderline personality
disorder, while Mark was diagnosed with narcissistic personality disorder,
based on interviews and tests conducted by a psychiatrist. The psychiatrist
concluded that both were psychologically incapacitated to perform their marital
obligations, rendering their marriage void.
The Regional Trial Court granted the petition, declaring the
marriage null and void. The Republic, through the Office of the Solicitor
General (OSG), opposed the ruling, arguing that the evidence of psychological
incapacity was insufficient, primarily because the psychiatric diagnosis of
Mark was not based on a direct examination but on collateral information.
The Court of Appeals affirmed the trial court's ruling,
finding that the totality of the evidence, including the expert testimony,
supported the conclusion that both parties were psychologically incapacitated.
The OSG appealed to the Supreme Court, questioning the sufficiency of the
evidence, particularly the psychiatric diagnosis of Mark.
Primary Issue:
Did the evidence sufficiently support the petition for the
declaration of nullity of the marriage based on both parties' psychological
incapacity, despite the absence of a direct psychiatric examination of one
spouse?
Supreme Court Decision:
The Supreme Court affirmed the decision of the Court of
Appeals, ruling that the totality of the evidence, including the testimony of
Angelique, her uncle, and the psychiatric diagnosis, sufficiently established
that both parties were psychologically incapacitated. The Court emphasized that
under Tan-Andal v. Andal, psychological incapacity is a legal concept,
not necessarily a medical one, and may be proven through clear and convincing
evidence, even without direct psychiatric examination of the incapacitated
spouse. The psychological incapacity must be grave, incurable, and have
juridical antecedence, which the Court found to be present in this case.
Dispositive Portion:
"The petition is DENIED. The Decision dated January 30,
2018, and the Resolution dated April 11, 2019, in CA-G.R. CV No. 107744 are
AFFIRMED. The marriage between Angelique Pearl O. Claur and Mark A. Claur is
declared VOID on the ground of their psychological incapacity. Accordingly,
their property relation as husband and wife is DISSOLVED. SO ORDERED."
Should psychological incapacity, as grounds for nullifying a
marriage, always require a direct psychiatric examination of both spouses, or
is the testimony of close relatives and a single spouse enough to sever the
marital bond?
Important Doctrines:
- Psychological
Incapacity as a Legal Concept
- Psychological
incapacity under Article 36 of the Family Code is a legal concept, not a
medical condition, and does not necessarily require a clinical diagnosis.
- Totality
of Evidence Rule
- Courts
may base the declaration of psychological incapacity on the totality of
evidence, including the testimony of lay witnesses, without necessitating
a direct psychiatric evaluation of both spouses.
- Juridical
Antecedence, Gravity, and Incurability
- For
psychological incapacity to void a marriage, it must be shown that the
condition existed before the marriage, is grave, and is incurable within
the meaning of the law, not necessarily in medical terms.
Classification of the Case:
Civil Law (Family Law)
Nature of the Case:
This case involves a petition for the declaration of nullity
of marriage under Article 36 of the Family Code due to psychological
incapacity. The petitioner sought to prove that the marriage was void ab initio
as both parties were psychologically incapacitated.
Parties:
Brief Summary:
Angelique Claur sought to void her marriage to Mark Claur,
citing their mutual psychological incapacity. The trial court and the Court of
Appeals ruled in favor of nullity, relying on the testimony of witnesses and
expert opinion. The Supreme Court affirmed, emphasizing that psychological
incapacity under Tan-Andal v. Andal is a legal concept that does not
always require a medical diagnosis.
Does treating psychological incapacity as a purely legal
concept ensure justice in nullity cases, or does it risk misuse of the law?
Share your thoughts below!
10 Important Doctrines for Social Media Posting
- Psychological
Incapacity as a Legal Concept:
It is a legal, not medical, concept under Article 36 of the Family Code. Proof of medical diagnosis is not mandatory. (Tan-Andal v. Andal; Republic v. Claur) - Totality
of Evidence Rule:
Courts may rely on witness testimony, behavior patterns, and circumstantial evidence to prove psychological incapacity. (Republic v. Claur) - Clear
and Convincing Evidence:
Psychological incapacity must be proven by clear and convincing evidence—more than preponderance but less than proof beyond reasonable doubt. (Tan-Andal v. Andal) - Juridical
Antecedence:
The psychological incapacity must exist prior to the marriage and must be proven through consistent behavior or personality structures. (Republic v. Claur) - Incurability
of Psychological Incapacity:
Incapacity must be incurable in the legal sense, meaning it fundamentally prevents compliance with marital obligations. (Tan-Andal v. Andal) - Role
of Expert Testimony:
Expert testimony, while helpful, is not required to establish psychological incapacity. Ordinary witnesses are sufficient. (Tan-Andal v. Andal) - Marriage
as a Legal Contract:
Marriage requires mutual love, respect, fidelity, and support. Failure due to psychological incapacity voids the contract. (Family Code; Republic v. Claur) - Not
Just Mild Peculiarities:
Psychological incapacity cannot be based on mild character flaws or temporary emotional outbursts. It must be grave and debilitating. (Tan-Andal v. Andal) - Focus
on Marital Obligations:
The incapacity must specifically render the spouse unable to fulfill essential marital duties. (Republic v. Claur) - No
Straitjacket Application:
Courts must approach each case uniquely, considering the totality of evidence and circumstances. (Tan-Andal v. Andal)
Factual Reference:
Nature of the Case: This is a civil law case,
specifically involving a petition for declaration of nullity of marriage
on the ground of psychological incapacity.
Parties: The Republic of the Philippines, through the
OSG, challenged the petition filed by Angelique Pearl Claur against her
husband, Mark Claur.
Brief Summary: Angelique Claur filed for nullity of
marriage, alleging that both she and her husband were psychologically
incapacitated to fulfill marital obligations. Despite the absence of a direct
psychiatric evaluation of Mark, the lower courts granted the petition. The
Court of Appeals affirmed. The Supreme Court ultimately ruled that psychological
incapacity is a legal concept and does not require clinical diagnosis,
affirming the nullity of the marriage based on clear and convincing evidence.
✅ Note: The answer key
will be provided at the end of the video, so stay tuned and test your
understanding!
📘 10 HOTS (Higher-Order
Thinking Skills) – Easy Multiple Choice Questions:
Choose the BEST answer for each question.
- Which
factor primarily led the Supreme Court to affirm the nullity of the
marriage between Angelique and Mark Claur?
a. Lack of financial support
b. Incompatibility in interests
c. Proven mutual psychological incapacity
d. Absence of marital consent - What
key principle did the Supreme Court emphasize in determining
psychological incapacity?
a. It must be proven through psychiatric testing only
b. It is a moral issue and not a legal matter
c. It is a legal concept proven through behavior and evidence
d. It can only be proven through one spouse’s testimony - What
type of behavior was cited as proof of psychological incapacity in this
case?
a. Regular marital disagreements
b. Occasional forgetfulness and miscommunication
c. Patterns of violence, manipulation, and abandonment
d. Differences in religious beliefs - What
evidence was accepted by the Court despite being partly hearsay?
a. Financial records of tuition payments
b. Psychiatric report based on interviews and testing
c. Emails between the spouses
d. CCTV footage of arguments - What
was the Republic's main argument on appeal to the Supreme Court?
a. The lower courts lacked jurisdiction
b. The parties were actually still living together
c. The psychological incapacity was not sufficiently proven
d. The petition was filed beyond the prescriptive period - What
is the legal consequence when a marriage is declared void due to
psychological incapacity?
a. The marriage remains valid but unenforceable
b. The spouses are legally separated
c. The marriage is void ab initio
d. The parties must file for annulment - Why
was Mark’s lack of direct psychiatric evaluation not fatal to the case?
a. He admitted to being incapacitated
b. The law requires only lay witness testimony
c. Psychological incapacity can be established without it
d. The psychiatrist interviewed him via phone - Which
behavior pattern was attributed to Angelique in the psychiatric
evaluation?
a. Obsessive planning and control
b. Borderline personality traits with suicidal tendencies
c. Extreme religious conservatism
d. Avoidance of all emotional expression - How
did the Court classify the findings of the psychiatrist despite the
hearsay rule?
a. Inadmissible
b. Merely persuasive
c. Acceptable if reasonably relied upon by experts
d. Invalid due to lack of direct contact - What
did the Supreme Court declare about the relationship between love and
legal obligation in marriage?
a. Love is optional, but fidelity is required
b. Marriage must be built solely on affection
c. A marriage without mutual love and respect cannot be protected by law
d. Legal obligations override emotional aspects in marriage
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