Cynthia E. Yambao vs. Republic of the Philippines and Patricio E.

Yambao
G.R. No. 184!"
#anuary $4% $11
Nachura% #.
Facts:
&fter "' years of marria(e% petitioner filed before the R)C of *a+ati% a petition prayin(
that her marria(e% to private respondent% be declared void by reason of the latter,s
psycholo(ical incapacity. Petitioner averred that throu(h all the years of their married
life% she -as the only one -ho earned a livin( and too+ care of the children. .er
husband% she alle(es% did nothin( but eat and sleep all day% and spend time -ith his
friends. /he also claims that% Patricio became insecure and 0ealous and -ould (et mad
every time he -ould see her tal+in( to other people% even to her relatives. 1t -as -hen
her husband started threatenin( to +ill her that she decided to leave the con0u(al abode
and live separately from him.

/he then consulted a psychiatrist -ho concluded that
respondent -as indeed psycholo(ically incapacitated to comply -ith the essential
marital obli(ations. 1n ans-erin( his -ife,s petition% private respondent denied all the
alle(ations therein.
1n resolvin( the issue in favor of the respondent% the R)C said that there -as failure on
the part of the petitioner to substantiate her claims. &lso the R)C too+ into account that
despite the utter irresponsibility of the respondent% he and petitioner -ere able to raise
their children to adulthood% (ot alon( -ith the petitioner,s parents and their marria(e
lasted -ell up to thirty years. 2n &ppeal to the C& the R)C decision -as affirmed%
additionally it held that petitioner failed to sho- that respondent -as psycholo(ically
incapacitated to comply -ith the essential obli(ations of marria(e. 1t pointed out that
respondent e3erted efforts to find a source of income to support his family. .o-ever% his
failure to find a suitable 0ob and the failure of his business ventures -ere not mental but
physical defects and% hence% could not be considered 4psycholo(ical incapacity5 as
contemplated under the la-. )his no- resulted in the appeal to the /upreme Court.
Issue: 6oes the totality of the evidence establish respondent,s psycholo(ical incapacity
to perform the essential obli(ations of marria(e7
Held: No% the /upreme Court denies the petition and affirms the C&. )he Court held
that there -as no sho-in( that respondent -as sufferin( from a psycholo(ical condition
so severe that he -as una-are of his obli(ations to his -ife and family. 2n the contrary%
respondent8s efforts% thou(h fe- and far bet-een they may be% sho-ed an
understandin( of his duty to provide for his family% albeit he did not meet -ith much
success. 9hether his failure -as brou(ht about by his o-n indolence or irresponsibility%
or by some other e3ternal factors% is not relevant. 9hat is clear is that respondent% in
sho-in( an a-areness to provide for his family% even -ith his many failin(s% does not
suffer from psycholo(ical incapacity.
Even in the psycholo(ical report of 6r. )olentino it -as never e3plained ho- the alle(ed
psycholo(ical incapacity manifested and if -as present durin( the instance of marria(e.
&ll the report stated -as :because one8s personality or character is formed early in life%
it has a clear &N)ECE6EN) and it has an endurin( pattern of inner e3perience that
deviates from the e3pectations of the individual8s culture%: )hat respondent% accordin( to
petitioner% :lac+ed effective sense of rational 0ud(ment and responsibility: does e;uate
to the incapability to meet marital obli(ations. .is refusal to help care for the children%
his ne(lect for his business ventures% and his alle(ed unbearable 0ealousy may indicate
some emotional turmoil or mental difficulty% but none have been sho-n to amount to a
psycholo(ical abnormality.
<astly% the Court held that article "! contemplates incapacity or inability to ta+e
co(ni=ance of and to assume basic marital obli(ations and not merely difficulty% refusal%
or ne(lect in the performance of marital obli(ations or ill -ill. )his incapacity consists of
the follo-in(> ?a@ a true inability to commit oneself to the essentials of marria(eA ?b@ this
inability to commit oneself must refer to the essential obli(ations of marria(e> the
con0u(al act% the community of life and love% the renderin( of mutual help% the
procreation and education of offsprin(A and ?c@ the inability must be tantamount to a
psycholo(ical abnormality.

1t is not enou(h to prove that a spouse failed to meet his
responsibility and duty as a married personA it is essential that he must be sho-n to be
incapable of doin( so due to some psycholo(ical illness.