Te vs Te

Te vs. Te
GR No. 161793, February 13, 2009

FACTS:

Petitioner Edward Te first met respondent Rowena Te in a gathering organized by the Filipino-
Chinese association in their college. Initially, he was attracted to Rowena’s close friend but, as the
latter already had a boyfriend, the young man decided to court Rowena, which happened in January
1996. It was Rowena who asked that they elope but Edward refused bickering that he was young and
jobless. Her persistence, however, made him relent. They left Manila and sailed to Cebu that month;
he, providing their travel money of P80,000 and she, purchasing the boat ticket.

They decided to go back to Manila in April 1996. Rowena proceeded to her uncle’s house and
Edward to his parents’ home. Eventually they got married but without a marriage license. Edward
was prohibited from getting out of the house unaccompanied and was threatened by Rowena and her
uncle. After a month, Edward escaped from the house, and stayed with his parents. Edward’s
parents wanted them to stay at their house but Rowena refused and demanded that they have a
separate abode. In June 1996, she said that it was better for them to live separate lives and they then
parted ways.

After four years in January 2000, Edward filed a petition for the annulment of his marriage to
Rowena on the basis of the latter’s psychological incapacity.

ISSUE: Whether the marriage contracted is void on the ground of psychological incapacity.

HELD:

The parties’ whirlwind relationship lasted more or less six months. They met in January 1996, eloped
in March, exchanged marital vows in May, and parted ways in June. The psychologist who provided
expert testimony found both parties psychologically incapacitated. Petitioner’s behavioral pattern
falls under the classification of dependent personality disorder, and respondent’s, that of the
narcissistic and antisocial personality disorder

There is no requirement that the person to be declared psychologically incapacitated be personally

examined by a physician, if the totality of evidence presented is enough to sustain a finding of
psychological incapacity. Verily, the evidence must show a link, medical or the like, between the
acts that manifest psychological incapacity and the psychological disorder itself.

The presentation of expert proof presupposes a thorough and in-depth assessment of the parties by
the psychologist or expert, for a conclusive diagnosis of a grave, severe and incurable presence of
psychological incapacity.

Indeed, petitioner, afflicted with dependent personality disorder, cannot assume the essential marital
obligations of living together, observing love, respect and fidelity and rendering help and support, for
he is unable to make everyday decisions without advice from others, and allows others to make most
of his important decisions (such as where to live). As clearly shown in this case, petitioner followed
everything dictated to him by the persons around him. He is insecure, weak and gullible, has no sense
of his identity as a person, has no cohesive self to speak of, and has no goals and clear direction in
life.

As for the respondent, her being afflicted with antisocial personality disorder makes her unable to
assume the essential marital obligations on account for her disregard in the rights of others, her
abuse, mistreatment and control of others without remorse, and her tendency to blame
others. Moreover, as shown in this case, respondent is impulsive and domineering; she had no
qualms in manipulating petitioner with her threats of blackmail and of committing suicide.

Both parties being afflicted with grave, severe and incurable psychological incapacity, the
precipitous marriage that they contracted on April 23, 1996 is thus, declared null and void.
Posted by hyper_jetsetter at 6:22:

579 SCRA 193 – Civil Law – Family Code – Article 36: Psychological Incapacity – Molina
Case Merely a Guideline
Every case involving psychological incapacity must be resolved on a case-to-case basis
Note: This case relaxed the application of the Molina Guidelines
Edward Kenneth Ngo Te met Rowena Ong Gutierrez Yu at a Filipino-Chinese gathering at a
school campus. They did not have interest with each other at first but they developed a
certain degree of closeness due to the fact that they share the same angst with their
families. In 1996, while still in college, Rowena proposed to Kenneth that they should elope.
Kenneth initially refused on the ground that he was still young and jobless. But due to
Rowena’s persistence Kenneth complied bringing with him P80K. The money soon after
disappeared and they found themselves forced to return to their respective home.
Subsequently, Rowena’s uncle brought the two before a court and had had them be
married. After marriage, Kenneth and Rowena stayed with her uncle’s house where
Kenneth was treated like a prisoner.
Meanwhile, Kenneth was advised by his dad to come home otherwise he will be
disinherited. One month later, Kenneth was able to escape and he was hidden from
Rowena’s family. Kenneth later contacted Rowena urging her to live with his parents
instead. Rowena however suggested that he should get his inheritance instead so that they
could live together separately or just stay with her uncle.
Kenneth however was already disinherited. Upon knowing this, Rowena said that it is better
if they live separate lives from then on. Four years later, Kenneth filed a petition for
annulment of his marriage with Rowena. Rowena did not file an answer. The City
Prosecutor, after investigation, submitted that he cannot determine if there is collusion
between the two parties. Eventually, the case was tried. The opinion of an expert was
sought wherein the psychologist subsequently ruled that both parties are psychologically
incapacitated. The said relationship between Kenneth and Rowena is said to be
undoubtedly in the wreck and weakly-founded. The break-up was caused by both parties’
unreadiness to commitment and their young age. Kenneth was still in the state of finding
his fate and fighting boredom, while Rowena was still egocentrically involved with herself.
The trial court ruled that the marriage is void upon the findings of the expert psychologist.
The Solicitor General (OSG) appealed and the Court of Appeals ruled in favor of the OSG.
The OSG claimed that the psychological incapacity of both parties was not shown to be
medically or clinically permanent or incurable (Molina case). The clinical psychologist did
not personally examine Rowena, and relied only on the information provided by Kenneth.
Further, the psychological incapacity was not shown to be attended by gravity, juridical
antecedence and incurability. All these were requirements set forth in the Molina caseto be
followed as guidelines.
ISSUE: Whether or not the expert opinion of the psychologist should be admitted in lieu of
the guidelines established in the landmark case of Molina.
HELD: Yes, such is possible. The Supreme Court ruled that admittedly, the SC may have
inappropriately imposed a set of rigid rules in ascertaining Psychological Incapacity in
the Molina case. So much so that the subsequent cases after Molina were ruled accordingly
to the doctrine set therein. And that there is not much regard for the law’s clear intention
that each case is to be treated differently, as “courts should interpret the provision on a
case-to-case basis; guided by experience, the findings of experts and researchers in
psychological disciplines, and by decisions of church tribunals.” The SC however is not
abandoning the Molina guidelines, the SC merely reemphasized that there is need to
emphasize other perspectives as well which should govern the disposition of petitions for
declaration of nullity under Article 36 such as in the case at bar. The principle that each
case must be judged, not on the basis of a priori assumptions, predilections or
generalizations but according to its own facts. And, to repeat for emphasis, courts should
interpret the provision on a case-to-case basis; guided by experience, the findings of
experts and researchers in psychological disciplines, and by decisions of church tribunals.
The SC then ruled that the marriage of Kenneth and Rowena is null and void due to both
parties’ psychological disorder as evidenced by the finding of the expert psychologist. Both
parties being afflicted with grave, severe and incurable psychological incapacity. Kenneth
cannot assume the essential marital obligations of living together, observing love, respect
and fidelity and rendering help and support, for he is unable to make everyday decisions
without advice from others. He is too dependent on others. Rowena cannot perform the
essential marital obligations as well due to her intolerance and impulsiveness.
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Comments
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161793, Jurisprudence, Kenneth Ngo Te vs Rowena Yu Te, marriage, molina case,molina
guidelines, molina vs ca, ngo te vs republic, ngo te vs yu te, Psychological Incapacity, scra, Te vs
Te, te vs yu-te, void marriage
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