Toring v. Toring (G.R. No. 165321; August 3, 2010)

CASE DIGEST: RICARDO P. TORING, Petitioner, v. TERESITA M. TORING and REPUBLIC OF THE PHILIPPINES, Respondents.

FACTS: Ricardo and Teresita were married and had 3 children. Ricardo then filed a petition for annulment based on Teresita psychological incapacity. He alleged that Teresita was an adulteress and a squanderer. The doctor who performed the psychological evaluation conducted on Ricardo and their son, Richardson, testified that the major factor that contributed to the demise of the marriage is Teresita Narcissistic Personality Disorder that rendered her incapable to fulfill her essential marital obligations.

ISSUE:

Is there sufficient basis to declare Ricardo and Teresita marriage void due to psychological incapacity?HELD: No. Psychological incapacity under Article 36 of the Family Code must be characterized by (a) gravity, (b) juridical antecedence, and (c) incurability, to be sufficient basis to annul a marriage. The psychological incapacity should refer to "no less than a mental (not physical) incapacity that causes a party to be truly incognitive of the basic marital covenants that concomitantly must be assumed and discharged by the parties to the marriage."

It is not acceptable that a mere narration of the statements of Ricardo and Richardson, coupled with the results of the psychological tests administered only on Ricardo, without more, already constitutes sufficient basis for the conclusion that Teresita suffered from Narcissistic Personality Disorder.