Case Digest: Buenaventura vs. Court of Appeals

NOEL BUENAVENTURA vs. COURT OF APPEALS and ISABEL LUCIA SINGH BUENAVENTURA

G.R. No. 127358                                  31 March 2005

Azcuna, J.

FACTS:

This case was instituted by Petitioner Noel Buenaventura where he stated that he and his wife, Isabel Lucia Singh Buenaventura, were both psychologically incapacitated to comply with the essential obligations of marriage. The lower court found that petitioner was merely under heavy parental pressure to marry, and deceived Private Respondent Isabel Singh to marry. Buenaventura was unable to relate to his wife, as a husband, and their son, Javy, as a father. Moreso, he had no inclination to make the marriage work such that in times of trouble, he’d rather choose to leave his family than reconcile with his wife.

ISSUE/S: 

1. Whether or not, based on the findings of the lower court, the marriage between Buenaventura and Singh may be declared null and void under Article 36 of the Family Code, due to the psychological incapacity of the petitioner.
2. Whether or not the award of moral damages to the aggrieved spouse is proper in such cases.

RULING:

1. Yes. The Court of Appeals and the trial court considered the acts of the petitioner after the marriage as proof of his psychological incapacity, and therefore a product of his incapacity or inability to comply with the essential obligations of marriage. Psychological incapacity has been defined, as no less than a mental (not physical) incapacity that causes a party to be truly incognitive of the basic marital covenants that concomitantly must be assumed and discharged by the parties to the marriage which, as so expressed by Article 68 of the Family Code, include their mutual obligations to live together, observe love, respect and fidelity and render help and support. There is hardly any doubt that the intendment of the law has been to confine the meaning of "psychological incapacity" to the most serious cases of personality disorders clearly demonstrative of an utter insensitivity or inability to give meaning and significance to the marriage.
2. Based on the above definition of psychological incapacity, by declaring the petitioner as psychologically incapacitated, the possibility of awarding moral damages on the same set of facts was negated. The award of moral damages should be predicated, not on the mere act of entering into the marriage, but on specific evidence that it was done deliberately and with malice by a party who had knowledge of his or her disability and yet wilfully concealed the same.