Weighing Evidence in Psychological Incapacity Cases Under Article 36

The Supreme Court recently addressed a recurring issue in marriage nullity cases: when a spouse challenges the trial court's finding of psychological incapacity, is the issue one of law or of fact? In Soto v. Reyes-Soto (G.R. No. 249759, April 22, 2026), the Court clarified that a petition questioning the sufficiency and credibility of evidence on psychological incapacity raises questions of fact, which are not reviewable under Rule 45 of the Rules of Court. The ruling reinforces the deference appellate courts give to trial court findings in these emotionally charged and fact-intensive cases.

The Facts of the Case

The petitioner and respondent met as college students, became a couple in 1981, and married in September 1983 after the respondent discovered she was pregnant. The couple lived with the respondent's parents, then with the petitioner's parents in Pasig City. The marriage deteriorated over the years due to the petitioner's emotional distance, his perceived dependence on his mother, and the couple's differing parenting styles.

The respondent testified that the petitioner rarely showed affection, that they had no intimate relations since 1986, and that their life together was monotonous and routine. In 1988, the petitioner moved to the United States for work. The respondent eventually declined to join him, and the couple lived separately for years. The petitioner filed for divorce in the United States in 1994.

In 2013, the respondent filed a petition for declaration of nullity of marriage under Article 36 of the Family Code.

The Trial Court and Court of Appeals Rulings

The Regional Trial Court granted the petition, relying on the testimonies of the respondent, her sister, and a psychiatrist, Dr. Cecilia Villegas. Dr. Villegas diagnosed the respondent with Passive-Aggressive Personality Disorder and the petitioner with Inadequate Personality Disorder, tracing both conditions to the parties' formative years and concluding that the disorders were grave and incurable.

The Court of Appeals initially reversed the RTC, but later granted the respondent's motion for reconsideration and reinstated the trial court's decision. The CA held that Dr. Villegas's findings adequately established the spouses' psychological incapacity under the standards set by Article 36.

The Issue Before the Supreme Court

The petitioner argued that the CA erred in finding psychological incapacity, insisting there was no adequate evidence of juridical antecedence, gravity, and incurability. He claimed that Dr. Villegas's testimony was not credible because her findings were based partly on psychological tests conducted by another person. The petitioner also argued that the respondent merely fell out of love and grew dissatisfied with her marriage.

The respondent countered that the petition raised questions of fact, which are improper in a Rule 45 petition.

The Supreme Court's Ruling

The Court held that the issues raised in the petition were questions of fact, not law. Quoting Roxaco-Asia Hospitality Corp. v. Gulf Canary Construction and Development, Inc., the Court explained that a question of law exists when the controversy concerns the correct application of law to a given set of facts. A question of fact, on the other hand, arises when the issue calls for an examination of the probative value of evidence, the credibility of witnesses, and the probability of factual inferences.

The Court noted that the petitioner did not dispute the existence of the testimonies presented. Instead, he attacked their sufficiency, credibility, and weight, insisting that Dr. Villegas's conclusions were unreliable. These contentions, the Court said, require a reassessment of evidence — an exercise beyond the Court's authority in a Rule 45 petition.

The Court emphasized that it is not a trier of facts. The factual findings of the RTC, affirmed by the CA after reconsideration, are binding upon the Court. None of the recognized exceptions to this rule applied.

What This Means for Similar Cases

The decision underscores the importance of presenting complete and credible evidence at the trial court level. In psychological incapacity cases, the trial court's factual findings — including its assessment of expert testimony — carry significant weight. A party who disagrees with those findings cannot simply relitigate the facts before the Supreme Court.

The ruling also affirms that a psychiatrist's expert opinion, when based on personal interviews with both parties and corroborated by psychological tests, can sufficiently establish psychological incapacity. The Court rejected the petitioner's argument that the psychiatrist's reliance on tests conducted by another professional rendered her findings hearsay.

Practical Takeaways

• Questions of fact vs. law: A Rule 45 petition must raise only questions of law. Challenges to the credibility or sufficiency of evidence are questions of fact and will not be entertained by the Supreme Court.
• Trial court findings are binding: Factual findings of the RTC, especially when affirmed by the CA, are generally conclusive on the Supreme Court.
• Expert testimony matters: A psychiatrist's findings, based on interviews with both parties and corroborated by psychological tests, can establish psychological incapacity under Article 36.
• Evidence must be complete at trial: Parties should present all available evidence at the trial court level, as appellate remedies are limited for factual disputes.
• Psychological incapacity is distinct from mere unhappiness: Courts require proof of juridical antecedence, gravity, and incurability — not just dissatisfaction or falling out of love.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.