19/09/2025
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| The Supreme Court (SC) ruled that being irresponsible in doing household chores and taking care of children may be considered evidence of psychological incapacity to comply with marital obligations, a ground for nullification of marriage.
In a 13-page decision authored by Associate Justice Samuel Gaerlan, the SC's Third Division has declared void from the beginning the marriage between Arnold Alfonso and Michelle Pamintuan-Alfonso on the ground of the latter's psychological incapacity as provided under Article 36 of the Family Code.
Arnold and Michelle were high school classmates. In 1997, or eight years after their graduation, they unexpectedly met. Since then, they have become close and regularly exchanged phone calls.
Despite being in a relationship with another man, Michelle often visited Arnold's apartment. Later on Michelle and Arnold spent the night at the latter's apartment, where the two engaged in unprotected sexual in*******se that resulted in Michelle's unexpected and unwanted pregnancy.
At first, Michelle was contemplating aborting the child, but Arnold convinced her otherwise and offered marriage. After the wedding, Michelle and Arnold resided at the parental house. They were blessed with three children.
A year later their relationship turned sour. Arnold noticed the changes in Michelle's behavior. Michelle would be verbally aggressive towards him, crying loudly to gain sympathy from their neighbors. She also refused to do household chores or care for their children, instead relying on her mother to fulfill her domestic responsibilities.
Arnold also observed that Michelle has a luxurious lifestyle, which caused her to obtain looming debts from various people. It reached the extent that Arnold's father paid Michelle's debt to save her from being sued.
Over time, Arnold felt Michelle's growing coldness towards him. Michelle disavowed fulfilling his sexual needs by making excuses that she is tired and not in the mood.
Sometime in 2010, Michelle informed Arnold that she had secured a job that required deployment to Bicol for one month. However, to his surprise, Arnold later learned that Michelle was having an affair with another man. Since then, Michelle has refused to communicate with him and their children.
This paved the way for Arnold to file a petition for nullification of their marriage on the ground of Michelle's psychological incapacity to fulfill her marital obligations.
Initially, the Regional Trial Court (RTC) granted the petition and nullified their marriage, but it was later reversed by the Court of Appeals. This prompted Arnold to elevate the case before the Supreme Court.
In granting Arnold's petition, the high court held that he was able to illustrate that the incapacity of Michelle was so grave or serious that it already impaired her from carrying out the required ordinary marital duties. It gave credence to the psychological report, which diagnosed Michelle with histrionic personality disorder and antisocial personality disorder.
The SC also emphasized that the incapacity of Michelle was incurable, as the pattern of persistent failure to assume her essential marital obligations was proven. It also took into account the instance where Michelle entered into an illicit affair with another man.
“In every marriage lies the vinculum juris—the juridical bond that unites the spouses in a legally and morally binding union governed by law. This vinculum juris imposes upon each spouse the essential marital obligations of mutual love, respect, fidelity, and support,” the Supreme Court said.
“Thus, in the present case, we hold that Michelle's psychological incapacity existed prior to and during the celebration of the marriage; the vinculum juris is deemed never to have validly arisen,” it added.
