03/01/2026
The marriage was declared VOID on the ground of the wife’s psychological incapacity, as she was found to be suffering from Narcissistic Personality Disorder with paranoid traits, classified as grave and incurable.
The Supreme Court stressed that psychological incapacity must be proven to have existed before or at the time the marriage was celebrated. It must likewise be shown that, because of such incapacity, the spouse consistently fails to perform the essential obligations of marriage.
Mere controlling or difficult behavior on the part of the wife is insufficient, the incapacity must be established through competent psychological expert testimony.
SUPREME COURT DECLARES MARRIAGE VOID DUE TO WIFE'S CONTROLLING CONDUCT
The Supreme Court (SC) has affirmed the Court of Appeals (CA) ruling that nullified the marriage of a couple on the ground of the wife's psychological incapacity demonstrated through her domineering and controlling attitude to the extent that she always demands her husband to always update her of his whereabouts.
In a 14-page decision authored by Associate Justice Henri Jean Paul Inting, the SC's Third Division has declared void from the beginning the marriage between a couple on the ground of the wife's psychological incapacity as provided under Article 36 of the Family Code.
The couple were married on January 22, 1995. They had no antenuptial agreement, and their property relations are governed by the regime of absolute community of property.
The husband narrated that even prior to the wedding, the psychological incapacity of his wife, whose childhood was marked with overindulgence at a time when her pathogenic family was still wealthy, was demonstrated by her domineering attitude coupled with her lazy and poor study habits.
He added that after the wedding, the wife's incapacity to perform her marital obligations supposedly became more apparent given that she continued to be domineering and controlling as she required the husband to always update her of his whereabouts. She also displayed an arrogant and haughty attitude, especially towards his mother.
More than these, the husband also claimed that the wife's psychologically abused their children when she physically attacked him in the presence of their kids while he was holding their daughter, and reached the point when she sneaked in the house of the husband's mother to take the kids home without telling anyone. This paved the way for him to file a petition for nullification of marriage.
A clinical psychologist testified that the wife suffered from Narcissistic Personality Disorder with paranoid features, which is categorized as grave, incurable, and with antecedents. The expert recommended the nullification of their marriage.
In her defense, the wife countered that it was the husband who abused their children, not only psychologically but also sexually. She averred that in times of disagreement, her husband also physically and verbally abused her.
The Regional Trial Court and Court of Appeals (CA) granted the petition and declared void ab initio their marriage. The CA gave much weight to the psychological reports, which showed that the wife's psychological incapacity is grave and incurable. Aggrieved the wife elevated the case before the Supreme Court.
In denying her appeal, the high court found no valid reason to overturn the consistent findings and conclusions of the RTC and the CA, which are supported by the evidence on record.
It cited the landmark case of Tan-Andal vs. Andal, which requires that in order to grant the nullification of marriage due to psychological incapacity, the same must be grave enough to cause the couple's inability, not mere refusal, neglect, or difficulty, to perform the essential marital obligations.
It must also be shown that the psychological incapacity existed prior to or at the time of the celebration of the marriage, and it must be proven that the spouse, by reason of his or her psychological incapacity, persistently fails to comply with the essential marital obligations.
The SC agreed to the CA finding that the evidence presented by the husband is sufficient to establish that the wife suffered from a narcissistic personality disorder with paranoid features through the accounts of his witnesses, corroborated by the psychological report and testimony of the clinical psychologist.
It also emphasized that the nature of the wife's psychological incapacity is severe and pervasive, citing the psychological reports that revealed it affects all areas of her life, to the point that she is unable to perform her essential marital obligations to her husband.
The high court also took into consideration that it is quite apparent that the wife's psychological incapacity, as shown by the behavioral manifestations of her personality disorder, existed even before their marriage, as the same is rooted in her childhood and carried over into her adulthood.
It ruled that since their marriage was declared void, the rules on co-ownership, in relation to Article 147 of the Family Code, govern the liquidation, partition, and distribution of their common properties.
Hence, the highest bench deemed it proper to remand the case back to the trial court, as it appears that both parties have raised issues regarding their property relations in their respective pleadings.
