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The Case of Rosana Tan-Andal V Mario M. Andal G.R. No. 196359. May 11, 2021

The Supreme Court ruled that the marriage between Rosana Tan-Andal and Mario M. Andal was null and invalid due to Mario's psychological incapacity. Throughout their marriage, Mario exhibited emotional immaturity, recklessness, anger issues and drug abuse. He would frequently leave the family home for days at a time, leaving Rosana to care for their daughter alone while working full time. Witnesses testified that Mario was unable to fulfill his responsibilities as a husband due to his mental illness. The Court found sufficient evidence that Mario's personality and behavior undermined the family relationship and made the marriage unable to survive.

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122 views1 page

The Case of Rosana Tan-Andal V Mario M. Andal G.R. No. 196359. May 11, 2021

The Supreme Court ruled that the marriage between Rosana Tan-Andal and Mario M. Andal was null and invalid due to Mario's psychological incapacity. Throughout their marriage, Mario exhibited emotional immaturity, recklessness, anger issues and drug abuse. He would frequently leave the family home for days at a time, leaving Rosana to care for their daughter alone while working full time. Witnesses testified that Mario was unable to fulfill his responsibilities as a husband due to his mental illness. The Court found sufficient evidence that Mario's personality and behavior undermined the family relationship and made the marriage unable to survive.

Uploaded by

Zach Cariño
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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The Case of Rosana Tan-Andal v Mario M. Andal G.R. No. 196359.

May 11, 2021

Facts
It was 1995 when Mario Victor Andal (Mario) married Rosanna Tan (Rosanna). Rosanna and Mario had a
daughter, Ma. Samantha, a year later. Emotional immaturity, recklessness, and anger were some of Mario's many
flaws throughout their marriage. In the presence of Ma. Samantha, Mario had been found to be under the influence
of a prohibited drug. Often, Mario would leave the family home for days at a time, leaving Rosanna to raise Ma.
Samantha is by herself and works full time. And Mario had kept Samantha from taking the meds she was supposed
to be taking for her health problems.
As a result, Rosanna filed a petition for divorce from Mario. Rosanna said that Mario is unable to perform
his responsibilities as a husband because of his mental illness. There is no doubt that Mario has a narcissistic
antisocial personality disorder and drug misuse problem with psychotic symptoms, according to Dr. Garcia's
evidence. Rosanna's petition was granted by the RT, which ruled Mario and Rosanna's marriage null and invalid.
The RTC's decision was rejected by the Court of Appeals (CA), which found that Dr. Garcia's expert evidence
lacked credibility since Mario had not been examined in person.

Issue
Is Mario and Rosanna's marriage null and invalid due to Mario's psychological incapacity?

Rule
Yes. Article 36 of the Family Code states that the marriage between Rosanna and Mario is null and
invalid. Rosanna was able to demonstrate conclusively that Mario was unable to fulfill his marriage responsibilities
because of his mental illness. The second Molina guideline was changed by the Court to indicate that psychological
incapacity is neither a mental incapacity nor a personality disorder that must be demonstrated by expert opinion
under the standards given by the Molina doctrine. A person's "personality structure," which is shown via evident
actions of dysfunctionality that undermine the family, must first be proven to have lasting or persistent
characteristics. He or she must be incapable of understanding and enforcing his or her marital responsibilities if the
marriage is to survive. "Mild characterological anomalies, mood fluctuations, occasional emotional outbursts" are
omitted from the definition of "gravity" in the sense that "serious or dangerous" mental disease is not required.
There is no need to rely on an expert to demonstrate these characteristics of one's personality. Witnesses
who were present in the lives of the spouses prior to their marriage may testify to the apparently impaired spouse's
continuous conduct. The court will next determine whether these acts are suggestive of a real and substantial
inability to undertake the necessary marital responsibilities. A court judged Mario incapable of fulfilling his
marriage responsibilities due to his mental incapacity. In order to annul her marriage to Mario, Rosanna met the
burden of evidence. Many witnesses testified to the fact that Mario was psychologically unfit to be Rosanna's
husband, particularly those who spoke about Mario's personality and how it was formed in his formative years and
as an adult.

Ria Camaclang
Zecariah Cariño

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