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VINAS VS. VINAS 5. On the other hand, Dr.

Tayag assessed Mary Graces


(G.R. No. 208790, January 21 2015) personality through the data she had gathered from Glenn and
his cousin, Rodelito Mayo (Rodelito), who knew Mary
FACTS Graceway back in college.

1. On April 26, 1999, Glenn and Mary Grace, then 25 and 23 6. Dr. Tayag diagnosed Mary Grace to be suffering from a
years old, respectively, got married in civil rites held in Lipa Narcissistic Personality Disorder with anti-social traits. Dr.
City, Batangas.4 Mary Grace was already pregnant then. The Tayag concluded that Mary Grace and Glenns relationship is
infant, however, died at birth due to weakness and not founded on mutual love, trust, respect, commitment and
malnourishment. Glenn alleged that the infants death was fidelity to each other.
caused by Mary Graces heavy drinking and smoking during
her pregnancy. 7. On January 29, 2010, the RTC rendered its Decision
declaring the marriage between Glenn and Mary Grace as null
2. In March of 2006, Mary Grace left the conjugal abode. and void on account of the latters psychological incapacity.
Glenn found out after that Mary Grace went to work in Dubai.
At the time the petition was filed Mary Grace had not returned 8. On January 29, 2013, the CA rendered the herein assailed
yet. decision reversing the RTC ruling and declaring the marriage
between Glenn and Mary Grace as valid and subsisting, citing
3. On February 18 2009 Glenn filed a petition for the the case of Santos vs CA where "psychological incapacity"
declaration of nullity of his marriage with Mary Grace. He should refer to no less than a mental (not physical) incapacity
alleged that Mary Grace was insecure, extremely jealous, that causes a party to be truly incognitive of the basic marital
outgoing and prone to regularly resorting to any pretext to be covenants.
able to leave the house. She thoroughly enjoyed the night life,
and drank and smoked heavily even when she was pregnant.
Further, Mary Grace refused to perform even the most essential ISSUE
household chores of cleaning and cooking.
WON Mary Grace was psychologically incapacitated
4. Glenn sought professional guidance and submitted himself to
a psychological evaluation by Clinical Psychologist Nedy
Tayag (Dr. Tayag). Dr. Tayag found him as "amply aware of
his marital roles" and "capable of maintaining a mature and
healthy heterosexual relationship.
HELD the respondents narcissistic personality disorder and to prove
that it existed at the inception of the marriage.
NO.
First, what she medically described was not related or linked to
While it is true that Glenns testimony was corroborated by Dr. the respondents exact condition except in a very general way.
Tayag, a psychologist who conducted a psychological
examination on Glenn, however, said examination was Second, her testimony was short on factual basis for her
conducted only on him and no evidence was shown that the diagnosis because it was wholly based on what the petitioner
psychological incapacity of Mary Grace was characterized by related to her.
gravity, juridical antecedence, and incurability.
It would be great injustice, to petitioner for the Court to give a The totality of the evidence presented provides inadequate
much too restrictive interpretation of the law and compel the basis for the Court to conclude that Mary Grace is indeed
petitioner to continue to be married to a wife who for purposes psychologically incapacitated to comply with her obligations as
of fulfilling her marital duties has, for all practical purposes, Glenns spouse.
ceased to exist
The petition is DENIED
The cumulative testimonies of Glenn, Dr. Tayag and Rodelito,
and the documentary evidence offered do not sufficiently prove
the root cause, gravity and incurability of Mary Graces
condition. The respondents stubborn refusal to cohabit with
the petitioner was doubtlessly irresponsible, but it was never
proven to be rooted in some psychological illness.

Dr. Tayags conclusions about the respondents psychological


incapacity were based on the information fed to her by only
one side the petitioner whose bias in favor of her cause
cannot be doubted.

The court finds that Dr. Tayags observations and conclusions


insufficiently in-depth and comprehensive to warrant the
conclusion that a psychological incapacity existed that
prevented the respondent from complying with the essential
obligations of marriage. It failed to identify the root cause of