By Gerome Dalipe IV
The Supreme Court has affirmed that testimonies from a spouse’s family and friends may be used to help establish psychological incapacity in cases seeking the nullity of marriage.
In a decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the SC Second Division upheld a ruling declaring the marriage of Jeffery A. Green and Rowena Manlutac Green null and void due to Rowena’s psychological incapacity.
Jeffery and Rowena had been in a relationship for four years before marrying.
Four years into their marriage, Jeffery filed a petition to nullify their union, claiming both he and Rowena were psychologically incapacitated.
In support of the petition, Jeffery submitted a psychiatric evaluation report based on standard tests and interviews with himself, Rowena, a mutual friend and Rowena’s mother.
According to the report, Rowena mismanaged their finances, incurred debts of up to PHP4 million and was accused of infidelity and dishonesty regarding the paternity of their child.
The Regional Trial Court granted the petition, which was later affirmed by the Court of Appeals and the Supreme Court.
The SC emphasized that testimonies from individuals close to the allegedly incapacitated spouse—such as family members or friends—can serve as reliable sources in psychological assessments, as they are less likely to be biased in favor of the petitioning spouse.
“This is a realistic reception of psychological assessments considering that the friends or relatives of the alleged psychologically incapacitated spouse will not be inclined to give hostile testimonies against the latter,” the SC held.
The High Court reiterated that under Article 36 of the Family Code, a marriage may be declared null and void if evidence shows that one party was psychologically incapacitated at the time of its celebration.
In this case, Jeffery presented documentation on Rowena’s financial issues, gambling, dishonesty and infidelity.
These were backed by a psychiatric report diagnosing her with incurable borderline personality disorder and antisocial personality disorder—conditions said to have stemmed from childhood trust issues and which rendered her incapable of fulfilling her marital obligations.
The SC cited findings that Rowena’s behavior—including her refusal to live with Jeffery, dishonesty about their child’s paternity, dependence on his support and spiraling debts—justified the annulment of the marriage.
