Baccay vs.

Baccay
Petitioner: Noel Baccay Respondent: Maribel Baccay and the Republic of the Philippines Ponente: Villarama, Jr.

Facts:

Noel and Maribel were in a relationship when they were in college Maribel proved to be invariably aloof and snobbish especially when invited by Noel to join the latter's family activities Sometime in 1997, Noel decided to break up with Maribel as he already had another girl Maribel refused. She accepted the relationship with the other woman just to keep her relationship with Noel They still continued to see each other on a "friendly" basis Despite the efforts to keep the meetings strictly friendly, both have had several romantic moments together In 1998, Maribel informed Noel that she was pregnant Noel grudgingly married Maribel later in 1998 They lived with Noel's parents Maribel, like before, remained aloof and snobbish towards Noel's family She also refused to have any sexual contact with Noel Noel never observed any symptoms of pregnancy in Maribel Maribel's officemates concurred in this observation In 1999, Maribel came home to announce that she had a miscarriage A month later, Noel confronted Maribel about the issue. It was a very heated discussion which caused Maribel to leave the house and never come back On Sept 2000, Noel filed a petition for declaration of nullity Maribel never heeded the summons They still continued the hearing as the prosecutor said that there was no collusion In Feb 2002, the RTC rendered a decision in favour of Noel Maribel failed to perform the essential marital obligations due to her Narcissistic Personality Disorder

Characterized by juridical antecedence, gravity, and incurability On appeal of the OSG, the CA reversed the decision of the RTC Noel failed to prove that the personality disorder was permanent and incurable She failed or refused to perform the marital obligations but she did not indicate incapacity Failure to have sexual intercourse was also not a ground since Noel admitted that they had occasions of sexual intimacy before the marriage In 2006, the CA denied Noel's motion for reconsideration Noel raised it to the SC Whether or not Maribel's failure to perform her essential marital obligations indicate psychological incapacity (36, FC) No, the petition lacks merit Grounds for psychological incapacity are found in Republic of the Phils. v. Court of Appeals Molina Doctrine In the case at hand, Noel's evidence was not sufficient to sustain a finding that Maribel was psychologically incapacitated He failed to prove the root cause of the alleged incapacity and establish the requirement of gravity, juridical antecedence, and incurability The psychologist who testified for Noel failed to establish how the psychological disorder of Maribel incapacitated Maribel from validly assuming the essential obligations of marriage The court said that the petitioner must prove that There is a psychological disorder Such disorder renders the other "truly incognitive of the basic marital covenants that concomitantly must be assumed and discharged by the parties to the marriage" Psychological incapacity must be more than just a "difficulty," a "refusal," or a "neglect"

Issue:

Held/ Ratio: