12 Republic of the Philippines vs Katrina Tabora-Tionglico AUTHOR: Buera

G.R. No. 218630 Date: January 11, 2018 Notes:

TOPIC: Psychological Incapacity
PONENTE: TIJAM, J;
CASE LAW/ DOCTRINE:
 Expert testimony cannot be given credence in cases involving psychological incapacity, if it was based
solely on the declarations of an interested party, such would constitute as hearsay and cannot be a
valid testimony.
FACTS:
 Katrina Tabora-Tionglico (petitioner) filed for a petition for declaration of nullity of her marriage under
Art. 36 (Psychological Incapacity). Petitioner was pregnant at a young age and eventually got married.
Their marriage was marred with bickering and quarrels, with her husband always going out with his
friends on late nights, and being dependent on his mother (Mama’s boy).
 Her husband questioned all petitioner’s decisions, from the upbringing of their child to the way she
treated the household help. All their fights resulted to Lawrence asking petitioner to leave the
household and never come back. Due to this, petitioner consulted with Dr. Arellano, a psychiatrist
who confirmed her beliefs that her husband has Narcissistic Personality Disorder based on
petitioner’s narrative and declared such as permanent, incurable and deeply integrated in his psyche,
meaning it was cultivated at a young age.

RTC – declared their marriage void ab initio

CA – Affirmed RTC decision causing the Office of the Solicitor General to file for certiorari in the Supreme Court
ISSUE(S): Whether or not the diagnosis of Dr. Arellano can be given credence as a ground to declare the
marriage void ab initio. NO.
RATIO:
 The court reiterated that in cases of psychological incapacity, the presence of expert testimony cannot
always be given credence, in fact it must be based on the totality of evidence adduced in the court
proceedings. In the case at bar, the diagnosis of Dr. Arellano was solely based on Katrina’s
statements without any participation of her husband, nor did Dr. Arellano invited or interviewed
Lawrence.
 As per the case of Rumbaua v. Rumbaua ‘to make conclusions and generalizations on the
respondent's psychological condition based on the information fed by only one side is, to our mind,
not different from admitting hearsay evidence as proof of the truthfulness of the content of such
evidence.' Therefore the court cannot give credence to Dr. Arellano’s diagnosis as he merely
diagnosed Lawrence in an indirect manner based only on petitioners declarations which would
more or less constitute as hearsay.