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, hed 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.
3. 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.