SC cancels marriage due to paranoid husband


In De La Fuente v. De La Fuente (G.R. No. 188400. March 8, 2017), the Supreme Court declared the marriage between Maria Teresa and Rodolfo.

Dr. Arnulfo V. Lopez (Dr. Lopez), a clinical psychologist, was presented as an expert witness. Dr. Lopez testified that he conducted an in-depth interview with Maria Teresa to gather information on her family background and her marital life with Rodolfo, and subjected her to a battery of psychological tests. Dr. Lopez also interviewed Rodolfo's best friend.

Dr. Lopez diagnosed Rodolfo with "paranoid personality disorder manifested by [Rodolfo's] damaging behavior like reckless driving and extreme jealousy; his being distrustful and suspicious; his severe doubts and distrust of friends and relatives of [Maria Teresa]; his being irresponsible and lack of remorse; his resistance to treatment; and his emotional coldness and severe immaturity."

Dr. Lopez stated that Rodolfo's disorder was one of the severe forms of personality disorder, even more severe than the other personality disorders like borderline and narcissistic personality disorders.38 Dr. Lopez explained that Rodolfo's personality disorder was most probably caused by a pathogenic parental model. Rodolfo's family background showed that his father was a psychiatric patient, and Rodolfo might have developed psychic contamination called double insanity, a symptom similar to his father's. Dr. Lopez further claimed that Rodolfo's disorder was serious and incurable because of his severe paranoia.

Dr. Lopez recommended that Maria Teresa and Rodolfo's marriage be annulled due to Rodolfo's incapacity to perform his marital obligations.
According to the Court, by the very nature of Article 36 (nullity due to psychological incapacity) of the Family Code, courts, despite having the ultimate task of decision-making, must give due regard to expert opinion on the psychological and mental disposition of the parties. The root cause of Rodolfo's paranoid personality disorder was hereditary in nature as his own father suffered from a similar disorder. Dr. Lopez stated that respondent's own psychological disorder probably started during his late childhood years and developed in his early adolescent years. Dr. Lopez explained that respondent's psychological incapacity to perform his marital obligations was likely caused by growing up with a pathogenic parental model.

Rodolfo's repeated behavior of psychological abuse by intimidating, stalking, and isolating his wife from her family and friends, as well as his increasing acts of physical violence, are proof of his depravity, and utter lack of comprehension of what marriage and partnership entail. The Supreme Court said it would be of utmost cruelty to decree that petitioner should remain married to respondent. After she had exerted efforts to save their marriage and their family, respondent simply refused to believe that there was anything wrong in their marriage. This shows that respondent truly could not comprehend and perform his marital obligations. This fact is persuasive enough for the Court to believe that respondent's mental illness is incurable.

HELD: WHEREFORE, premises considered, the Petition is GRANTED. The marriage of Maria Teresa Tani-De La Fuente and Rodolfo De La Fuente is declared NULL and VOID.

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