The Supreme Court has upheld the nullification of a marriage after ruling that the wife was psychologically incapacitated to fulfill her essential marital obligations due to persistent controlling and abusive behavior toward her husband.
In a decision dated August 2025, the High Court affirmed earlier rulings by the Pasig Regional Trial Court and the Court of Appeals, which declared void a marriage solemnized in 1995. The case stemmed from a petition filed by the husband in 2003, where he described his wife as domineering, excessively demanding, and deeply suspicious, including repeatedly accusing him of inappropriate relations with his own mother.
Court records noted allegations of both verbal and physical abuse, alongside constant monitoring of the husband’s whereabouts. A clinical assessment presented during trial diagnosed the wife with Narcissistic Personality Disorder with paranoid features, concluding that her condition was grave, rooted in her personality structure, and incurable—rendering her incapable of meeting marital responsibilities.
The wife disputed the ruling, arguing that the diagnosis was unfair because she was not personally examined and that her accusations of abuse against her husband and their children were not given due weight. However, the Supreme Court ruled that her refusal to undergo psychological evaluation justified reliance on collateral information, including testimonies and documented behavior.
Citing the landmark case Tan-Andal vs. Andal, the Court reiterated that psychological incapacity must be serious, existing before or during the marriage, and incurable. It concluded that the wife’s actions clearly showed a failure to uphold mutual love, respect, and support—core duties of marriage under the Family Code. The case was remanded to the Pasig RTC for determination of support and division of conjugal properties.
