Immaturity not a ground for Psychological Incapacity

Mendoza v. Republic of the Philippines

G.R. No. 15!"#$ November 1%$ %&1%
'ersamin$ (.)
*acts)
Petitioner and Dominic got married on her eighth month of pregnancy in civil rites
solemnized in Pasay City on June 24,1991, after which they moved to her place,
although remaining dependent on their parents for support Dominic remained !o"less
and dependent upon his father for support until he finished his college course in
#cto"er 199$ %he too& on various !o"s to meet the family's needs (fter graduation of
Dominic, he sold )cyclopedia's and eventually got a !o" in *oyota as a salesman +n
%eptem"er 1994, she discovered his illicit relationship with ,aida, his co-employee at
*oyota .otors )ventually, communication "etween them "ecame rare until they started
to sleep in separate rooms Dominic fails to support his family despite his earning
/orse, he was fired and was held criminally lia"le for violation of estafa and 0P 22 #n
#cto"er 11, 1992, Dominic a"andoned the con!ugal a"ode "ecause petitioner as&ed
him for 3time and space to thin& things over4 ( month later, she refused his attempt at
reconciliation, causing him to threaten to commit suicide (t that, she and her family
immediately left the house to live in another place concealed from him 5er petition for
declaration of nullity of marriage "ased on psychological incapacity of her hus"and was
approved "y the 6*C "ut was denied "y the Court of (ppeals due to lac& of evidence
hence this petition to the %upreme Court
Issue)
/hether or not the petition should "e granted
+eld)
7o *he C( correctly indicated that the ill-feelings that she har"ored towards Dominic,
which she admitted during her consultation with Dr %amson, furnished the "asis to
dou"t the findings of her e8pert witness9 that such findings were one-sided, "ecause
Dominic was not himself su"!ected to an actual psychiatric evaluation "y petitioner's
e8pert9 and that he also did not participate in the proceedings9 and that the findings and
conclusions on his psychological profile "y her e8pert were solely "ased on the self-
serving testimonial descriptions and characterizations of him rendered "y petitioner and
her witnesses .oreover, the only people Dr %amson interviewed a"out Dominic were
those whom petitioner herself referred
+n Dagdag, the Court ruled that 3)rlinda failed to comply with guideline 7o 2 which
re:uires that the root cause of psychological incapacity must "e medically or clinically
identified and sufficiently proven "y e8perts, since no psychiatrist or medical doctor
testified as to the alleged psychological incapacity of her hus"and4 0ut here, the
e8pert's testimony on Dominic's psychological profile did not identify, much less prove,
the root cause of his psychological incapacity "ecause said e8pert did not e8amine
Dominic in person "efore completing her report "ut simply relied on other people's
recollection and opinion for that purpose Dominic's alleged immaturity, deceitfulness
and lac& of remorse for his dishonesty and lac& of affection did not necessarily
constitute psychological incapacity )motional immaturity and irresponsi"ility did not
e:uate with psychological incapacity 7or were his supposed se8ual infidelity and
criminal offenses manifestations of psychological incapacity *he acts of dominic would
only constitute legal separation under (rticle 11 of the ;amily Code
5ence the petition of (ra"elle .endoza is denied