Psychological Incapacity Case: Chi Ming Tsoi vs CA (G.R. No. 119190 Jan. 16, 1997)

Chi Ming Tsoi vs Court of Appeals and Gina Lao Tsoi
G.R. No. 119190 Jan. 16, 1997

Facts:

Chi Ming Tsoi and Gina Lao married sometime on May 22, 1988. However, since their marriage and cohabitation for 10 months, the wife stated that there was no sexual interaction between them. This claim was also affirmed by the husband. Frustrated, Gina filed an annulment case against her husband on the ground of psychological incapacity for being unable to fulfill the basic marital obligations. RTC granted the annulment and was also affirmed by the CA. Hence, the petition.

Issue:

Whether or not the inability of the husband to have sexual intercourse with his wife for more than 10 months constitute a ground for annulment by reason of psychological incapacity.

Ruling:

One of the basic marital obligations under the Family Code is “To procreate children  based on the universal principle that procreation of children through sexual cooperation is the basic end of marriage.” Constant non-fulfillment of this obligation will finally destroy the integrity and wholeness of the marriage. Sexual intimacy is a gift and a participation in the mystery of creation.

The prolonged and senseless refusal of the husband to fulfill such marital obligation is equivalent to psychological incapacity.


Hereby, SC affirmed CA’s ruling.
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