August 18, 2010
Ponente: Nachura, J.
Topic: Psychological Incapacity - Anti-social
SUMMARY:
Maria and Ramon’s romance, which blossomed in UP Diliman,
led to their eventual marriage. Their marital bliss, however, was short-lived
as Ramon started to become withdrawn, uncaring, and apathetic to the financial
and emotional needs of his wife and children. On top of this, he had a drug
problem and an extra-marital affair. Upon Maria’s initiative, the RTC declared
their marriage null and void on the ground that Ramon was suffering from an
antisocial personality disorder, which rendered him psychologically
incapacitated to perform the essential marital obligations. Ramon appealed to
the CA, which reversed the RTC ruling and held that because the doctor-witnesses
were not able to personally examine Ramon, their psychiatric findings were mere
hearsay and were therefore inadmissible in evidences. The SC reversed the CA
and reinstated the RTC’s ruling because...
DOCTRINE:
…the lack of personal examination and interview of a person
diagnosed with personality disorder, does not per se invalidate the testimonies
of the doctors. Neither do their findings automatically constitute hearsay that
would result in their exclusion as evidence. Within their acknowledged field of
expertise, doctors can diagnose the psychological make-up of a person based on
a number of factors culled from various sources.
Patients with antisocial personality disorder can often seem
to be normal and even charming and ingratiating. Their histories, however,
reveal many areas of disordered life functioning. Lying, truancy, running away
from home, thefts, fights, substance abuse, and illegal activities are typical
experiences that patients report as beginning in childhood. Their own
explanations of their antisocial behavior make it seem mindless, but their mental
content reveals the complete absence of delusions and other signs of irrational
thinking. In fact, they frequently have a heightened sense of reality testing
and often impress observers as having good verbal intelligence. Those with this
disorder do not tell the truth and cannot be trusted to carry out any task or
adhere to any conventional standard of morality. A notable finding is a lack of
remorse for these actions; that is, they appear to lack a conscience.
FACTS:
In 1972, Ramon Reyes, a UPLB student, cross-enrolled in UP
Diliman where he met Maria Socorro Camacho, a Sociology major and a classmate
of his in one of his subjects. They were both 19 at the time.
Maria, an academic achiever and a perfectionist, was
attracted to Ramon, whom she thought was free-spirited and bright.
Subsequently, their casual acquaintanceship quickly developed into a
boyfriend-girlfriend relationship.
Since both resided in Mandaluyong City, they saw each other
every day and drove home together from UP. Maria enjoyed Ramon’s style of
courtship, which included dining out, unlike other couples their age who were
restricted by a measly student budget; Ramon’s family owned the Aristocrat
Restaurant, where he held a job.
Maria’s good impression of Ramon was not diminished by the
latter’s habit of cutting classes, not even by her discovery that he was taking
marijuana.
In 1975, Maria obtained her degree in AB Sociology. As for
Ramon, he had dropped out of UP on his third year (1974) and just continued to
work for the Aristocrat Restaurant.
In 1976, following Maria’s graduation and her father’s
death, Maria and Ramon got married. At that time, Maria was already five (5)
months pregnant and employed at the Population Center Foundation.
The newlyweds lived with Ramon’s family in Mandaluyong City.
All living expenses were shouldered by Ramon’s parents, and the
couple's respective salaries were spent solely for their personal
needs.
Financial difficulties started in 1977 after the birth of
their first child. Ramon used to give Maria a monthly allowance of P1,500 from
his salary, but this stopped after only a year.
Ramon resigned from Aristocrat and ventured in what turned
out to be a string of failed businesses:
o Ramon started by trading seafood in the province,
supplying hotels and restaurants, including the Aristocrat Restaurant. This
business, which required Ramon to go out of town for days on end without communication,
failed.
o A fishpond in Mindoro was similarly unsuccessful. That his
business took him away from his family did not seem to bother Ramon; he did not
exert any effort to remain in touch with them while he was away in Mindoro.
o The next business venture was scrap paper and carton
trading. This business failed and added to Ramon’s and Maria's trail of
debt.
Alongside the failure of these business ventures was the
gradual deterioration of the Reyes couple’s marriage.
With the hopes of making Ramon assume more responsibility,
Maria suggested that they live separately from her in-laws. This turned out to
be even more financially challenging for the young family.
With Ramon out of town all the time, with zero attempt at
communicating with his family and zero financial support, Maria had to take
care of all her family’s needs alone. Struggling and unable to deal, Maria,
together with Ramon and their children, decided to move in to her mother’s
house.
As if being the sole breadwinner and putting up with Ramon’s
lackadaisical attitude weren’t enough, Maria had to deal with her husband’s
irrational antics:
o When Maria, who had a prior miscarriage, gave birth to
their third son, Ramon was nowhere to be found. He surfaced a week later,
played nonchalantly with the baby, and made no inquiry whatsoever as to how she
was doing or how the hospital bills were settled.
o Maria heard Ramon talking over the phone with his former
secretary, asking if she liked his gift. The girl turned out to be his
mistress. This was the time when Ramon wasn’t providing for his family.
o When Maria had to be operated on for the removal of a
cyst, she requested Ramon to accompany her as she was wheeled into the
operating room. Ramon never did; he simply picked up a newspaper and read,
remaining unconcerned and unattentive to his wife’s impending surgery.
o Willing to give Ramon and their marriage another shot,
Maria conferred with his siblings and sought for intervention. Even Ramon’s own
siblings found him hopeless, but one of his brothers sponsored him and Maria to
a marriage encounter group. Ramon was uncooperative, so this intervention did
not yield any positive result.
o As a last ditch attempt to find out what's wrong
with Ramon and make him treat Maria and their children better, one of Ramon’s
brothers brought him to a psychologist. Ramon refused to undergo the
recommended psychotherapy treatment.
In 1997, Maria kicked Ramon out of the house. He left
willfully.
With the de facto separation, the relationship still did not
improve. Neither did Ramon’s relationship with his children.
In 2001, over 20 years after getting married, Maria filed
before the RTC a petition for the declaration of nullity of her marriage with
Ramon, alleging the latter’s psychological incapacity to fulfill the essential
marital obligations under Article 36 of the Family Code.
[RTC]: After trial, the RTC granted the petition and
declared the marriage between the parties null and void on the ground of their
psychological incapacity. RTC relied heavily on the oral and documentary
evidence obtained from the three experts i.e., Doctors Magno, Dayan and
Villegas.
Ramon, adamant on the validity of his marriage to Maria,
appealed to the CA.
[CA: Reversed the RTC ruling. The CA held that Ramon’s
psychological incapacity was ]not sufficiently established on account of the
fact that the findings of Dr. Magno and Dr. Villegas were made without having
personally examined Ramon.
Hence, the instant petition.
RULING:
Whether the
psychological incapacity of Ramon was sufficiently established. – YES.
Whether the marriage
between Ramon and Maria should be declared null and void on the ground of Ramon’s
psychological incapacity. – YES.
Contrary to the CA’s ruling that the fact of Ramon’s
psychological incapacity was not sufficiently established, three experts were
one in diagnosing Ramon with a personality disorder.
[Dra. Cecilia C. Villegas]
The 9th of 11 siblings, Ramon was acknowledged as the
favorite of his mother, and was described to have a close relationship with
her. At an early age, he manifested clinical behavior of conduct disorder and
was on marijuana regularly. His decision making is characterized by poor
impulse control, lack of insight and primitive drives. He seemed to feel more
comfortable in being untraditional and different from others. Preoccupation is
centered on himself, an unconscious wish for the continuance of the gratification
of his dependency needs, in his mother-son relationship.
From this stems his
difficulties in heterosexual relationship with his wife Maria, as pressures,
stresses, demands and expectations filled up in their marital relationship.
Strong masculine strivings is projected. For an intelligent person like Ramon,
he may sincerely want to be able to assume his duties and responsibilities as a
husband and father, but because of a severe psychological deficit, he was
unable to do so. The root cause of the above clinical conditions is due to his
underlying defense mechanisms, or the unconscious mental processes, that the
ego uses to resolve conflicts. It existed before marriage, but became manifest
only after the celebration, due to marital demands and stresses.
[Dr. Natividad A. Dayan]
Ramon seems to be very good at planning and starting things
but is unable to accomplish anything. He is unable to give priority to the
needs of his family. He has a small need of companionship and is most
comfortable alone. He exhibits withdrawal patterns. He has deep feelings of
inadequacy. Due to low self-esteem, he tends to feel inferior and to exclude
himself from association with others. He feels that he is different and as a
result is prone to anticipate rejections. Because of the discomfort produced by
these feelings, he is apt to avoid personal and social involvement, which
increases his preoccupation with himself and accentuates his tendency to
withdraw from interpersonal contact. He suffers from Mixed Personality Disorder
[Schizoid, Narcissistic and Antisocial Personality Disorder].
[Dr. Estrella T. Tiongson-Magno]
Ramon suffers from an antisocial personality disorder with
narcissistic and dependent features that renders him too immature and
irresponsible to assume the normal obligations of a marriage. Ramon’s
narcissistic personality features were manifested by his self-centeredness
(e.g. moved to Mindoro and lived there for 10 years, leaving his family in
Manila); his grandiose sense of self-importance (e.g. he would just come and
go, without telling his wife his whereabouts, etc.); his sense of entitlement
(e.g. felt entitled to a mistress because [petitioner] deprived him of his marital
rights, etc.); interpersonally exploitative (e.g. let his wife spend for all the
maintenance needs of the family, etc.); and lack of empathy (e.g. when asked to
choose between his mistress and his wife, he said he would think about it,
etc.) The aggressive sadistic personality features were manifested whom he has
physically, emotionally and verbally abusive [of] his wife when high on drugs;
and his dependent personality features were manifested by his need for others
to assume responsibility for most major areas of his life, and in his
difficulty in doing things on his own.
Whether the findings
of Doctors Magno and Villegas on the psychological incapacity of Ramon can be
validly admitted in evidence despite their not having personally examined
Ramon. – YES.
The lack of personal examination and interview of Ramon, or
any other person diagnosed with personality disorder, does not per se
invalidate the testimonies of the doctors. Neither do their findings
automatically constitute hearsay that would result in their exclusion as
evidence.
For one, marriage, by its very definition, necessarily
involves only two persons. The totality of the behavior of one spouse during
the cohabitation and marriage is generally and genuinely witnessed mainly by
the other. In this case, the experts testified on their individual assessment
of the present state of the parties marriage from the perception of one of the
parties, herein petitioner. Certainly, petitioner, during their marriage, had
occasion to interact with, and experience, respondents pattern of behavior
which she could then validly relay to the clinical psychologists and the
psychiatrist.
The clinical psychologists and psychiatrists assessment were
not based solely on the narration or personal interview of the petitioner.
Other informants such as respondents own son, siblings and in-laws, and
sister-in-law (sister of petitioner), testified on their own observations of
respondents behavior and interactions with them, spanning the period of time
they knew him. These were also used as the basis of the doctor’s assessments.
Within their acknowledged field of expertise, doctors can
diagnose the psychological make-up of a person based on a number of factors
culled from various sources. A person afflicted with a personality disorder
will not necessarily have personal knowledge thereof. In this case, considering
that a personality disorder is manifested in a pattern of behavior,
self-diagnosis by the respondent consisting only in his bare denial of the
doctors separate diagnoses, does not necessarily evoke credence and cannot
trump the clinical findings of experts.
In the case at bar, however, even without the experts’ conclusions
above, the factual antecedents (narrative of events; SEE FACTS) alleged in the
petition and established during trial, all point to the inevitable conclusion
that Ramon is psychologically incapacitated to perform the essential marital
obligations.
Whether Maria is also
psychologically incapacitated to perform her essential marital obligations. –
NO.
Dr. Villegas found that Maria was suffering from an
Inadequate Personality Disorder. In her diagnosis, Dr. Villegas opined that
Maria manifested inadequacies along her affective sphere that made her less
responsive to the emotional needs of her husband, who needed a great amount of
it, rendering her relatively psychologically incapacitated to perform the
duties and responsibilities of marriage.
Dr. Magno’s diagnosis of Maria’s psychological makeup was
along the same vein as that of Dr. Villegas’ : Maria is a good, sincere, and
conscientious person and she has tried her best to provide for the needs of her
children. Her achievements in this regard are praiseworthy. But she is
emotionally immature and her comprehension of human situations is very shallow
for a woman of her academic and professional competence. And this explains why
she married Ramon even when she knew he was a pothead, then despite the abuse,
took so long to do something about her situation.
Such findings, however, cannot be given weight. A perusal of
the Amended Petition shows that it failed to specifically allege the complete
facts showing that Maria was psychologically incapacitated from complying with
the essential marital obligations.
But even then, Maria's diagnosed condition is not a
debilitating psychological condition that incapacitates her from complying with
the essential marital obligations of marriage. In fact, in the Psychological
Evaluation Report of clinical psychologist Magno, Maria was given a glowing
evaluation as she was found to be a good, sincere, and conscientious person.
Even in Dr. Villegas’ psychiatric report, it was stated that Maria was able to
remain in their marriage for more than 20 years trying to reach out and lending
a hand for better understanding and relationship.
Therefore, the SC finds it hard to believe that Maria is psychologically
incapacitated within the contemplation of Article 36 of the Family Code.
What are personality
disorders? What are the diagnostic criteria for Antisocial Personality
Disorder?
The Diagnostic and Statistical Manual of Mental Disorders,
Fourth Edition (DSM IV) provides the general diagnostic criteria for
personality disorders:
o An enduring pattern of inner experience and behavior that
deviates markedly from the expectations of the individual's culture.
This pattern is manifested in two (2) or more of the following areas:
(1) cognition (i.e., ways of perceiving and interpreting
self, other people, and events)
(2) affectivity (i.e., the range, intensity, liability, and
appropriateness of emotional response)
(3) interpersonal functioning
(4) impulse control
o The enduring pattern is inflexible and pervasive across a
broad range of personal and social situations.
o The enduring pattern leads to clinically significant
distress or impairment in social, occupational or other important areas of
functioning.
o The pattern is stable and of long duration, and its onset
can be traced back at least to adolescence or early adulthood.
o The enduring pattern is not better accounted for as a
manifestation or a consequence of another mental disorder.
o The enduring pattern is not due to the direct
physiological effects of a substance (i.e., a drug of abuse, a medication) or a
general medical condition (e.g., head trauma).
The DSM IV outlines the diagnostic criteria for Antisocial
Personality Disorder:
o There is a pervasive pattern of disregard for and
violation of the rights of others occurring since age 15 years, as indicated by
three (or more) of the following:
(1) failure to conform to social norms with respect to
lawful behaviors as indicated by repeatedly performing acts that are grounds
for arrest
(2) deceitfulness, as indicated by repeated lying, use of
aliases, or conning others for personal profit or pleasure
(3) impulsivity or failure to plan ahead
(4) irritability and aggressiveness, as indicated by
repeated physical fights or assaults
(5) reckless disregard for safety of self or others
(6) consistent irresponsibility, as indicated by repeated
failure to sustain consistent work behavior or honor financial obligations
(7) lack of remorse as indicated by being indifferent to or
rationalizing having hurt, mistreated, or stolen from another
o The individual is at least 18 years.
o There is evidence of conduct disorder with onset before
age 15 years.
o The occurrence of antisocial behavior is not exclusively
during the course of schizophrenia or a manic episode.