Halili v.Halili, G.R. No. 165424, June 9, 2009

FACTS: Petitioner Lester Benjamin S. Halili filed a petition to declare his marriage to respondent Chona M. Santos-Halili null and void on the basis of his psychological incapacity to perform the essential obligations of marriage. He alleged that he wed respondent in civil rites thinking that it was a “joke.” After the ceremonies, they never lived together as husband and wife, but maintained the relationship. However, they started fighting constantly a year later, at which point petitioner decided to stop seeing respondent and started dating other women. Immediately thereafter, he received prank calls telling him to stop dating other women as he was already a married man. It was only upon making an inquiry that he found out that the marriage was not “fake.” Eventually, the RTC found petitioner to be suffering from a mixed personality disorder, particularly dependent and self-defeating personality disorder, as diagnosed by his expert witness, Dr. Natividad Dayan. The court a quo held that petitioner’s personality disorder was serious and incurable. CA reversed RTC’s decision.

ISSUE: W/N he is psychologically incapacitated

HELD: The testimony of petitioner’s expert witness revealed that petitioner was suffering from dependent personality disorder. In her psychological report, Dr. Dayan stated that petitioner’s dependent personality disorder was evident in the fact that petitioner was very much attached to his parents and depended on them for decisions. Petitioner’s mother even had to be the one to tell him to seek legal help when he felt confused on what action to take upon learning that his marriage to respondent was for real. Dr. Dayan further observed that petitioner typically acted in a self-denigrating manner and displayed a self-defeating attitude. This submissive attitude encouraged other people to take advantage of him. This could be seen in the way petitioner allowed himself to be dominated, first, by his father who treated his family like robots and, later, by respondent who was as domineering as his father. When petitioner could no longer take respondent’s domineering ways, he preferred to hide from her rather than confront her and tell her outright that he wanted to end their marriage. It has been sufficiently established that petitioner had a psychological condition that was grave and incurable and had a deeply rooted cause.