26/06/2025
The (SC) has ruled that a spouse’s inability to love or emotionally connect with their partner, if rooted in a genuine personality disorder, may be considered evidence of psychological incapacity and a ground to declare a marriage void.
In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC’s Second Division reinstated an earlier ruling of the Regional Trial Court (RTC) which declared a couple’s marriage void from the beginning due to the husband’s psychological incapacity to fulfill his marital duties.
The couple met in 1999 and married in 2002. They did not live together immediately, as the husband worked in Saudi Arabia. They were only physically together for about five years, and their relationship was marked by frequent arguments and periods of separation.
In 2016, the husband filed a petition to nullify the marriage, supported by a psychologist’s diagnosis of his Passive-Aggressive Personality Disorder, which made it difficult for him to maintain close relationships. The RTC initially granted his petition, but reversed the same on reconsideration. The Court of Appeals denied the husband’s appeal.
The SC, however, ruled in favor of the husband, finding that he had sufficiently proven psychological incapacity.
Under Article 36 of the Family Code, a marriage is void if one or both spouses are psychologically unable to fulfill their marital duties—even if the condition becomes evident only after the wedding. The incapacity must be deeply rooted in the person’s character and must have existed before the marriage.
The SC clarified that psychological incapacity can manifest long after the wedding, so a spouse who initially appears capable may later show signs of inability. If this comes from a genuine psychological condition, the marriage can still be declared void.
In this case, the SC found that the husband’s emotional detachment stemmed from a strict and emotionally distant upbringing. While he could provide for his family financially, he struggled to meet his wife’s emotional needs, including basic companionship.
Read the full text of the Press Release at https://tinyurl.com/2zjba472.
Read the full text of the Decision at https://tinyurl.com/8e67mcme.
Read the Dissenting Opinion of Associate Justice Jhosep Y. Lopez at https://tinyurl.com/56e9rs43.
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