The Supreme Court (SC) Second Division has reaffirmed that testimonies from family and friends may help establish psychological incapacity in petitions for the declaration of nullity of marriage.

In a decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the Court granted the petition to declare the marriage between Rowena Manlutac Green and Jeffery A. Green null and void on the ground of psychological incapacity.

“Psychological assessments based on the testimonies of the petitioner, respondent, respondent’s mother, and the spouses’ mutual friend may be given credence—unless there are reasons to believe that the testimonies are fabricated,” the decision stated.

FACTS

Jeffery filed a petition for the declaration of nullity of marriage against Rowena before the Regional Trial Court (RTC), citing psychological incapacity on both sides. 

He submitted documentary evidence of Rowena’s infidelity, dishonesty, and financial debts, along with a Psychiatric Evaluation Report based on standardized psychological tests and interviews with himself, Rowena, her mother, and a mutual friend.

The RTC granted the petition, finding insufficient evidence to prove Jeffery’s alleged psychological incapacity but recognizing Rowena’s condition.

Rowena moved for reconsideration, but the RTC denied it. She then elevated the case to the Court of Appeals (CA).

The CA affirmed the RTC’s decision, ruling that Rowena was afflicted with a psychological impairment at the time of the marriage—one that prevented and would continue to prevent her from fulfilling essential marital obligations.

RULING

The SC upheld the CA’s ruling and reiterated that psychological incapacity, under prevailing jurisprudence, is a legal—not medical—concept. 

The High Court stressed that testimonies from those closely familiar with a spouse’s behavior may be sufficient to establish psychological incapacity.

“This is a realistic reception of psychological assessments, considering that friends or relatives of the alleged psychologically incapacitated spouse are unlikely to offer hostile testimonies. Unless these testimonies are falsified to favor the petitioning spouse, they should be considered,” the decision read.

“[P]sychological incapacity consists of clear acts of dysfunctionality that show a lack of understanding and concomitant compliance with one’s essential marital obligations due to psychic causes. It is not a medical illness that must be clinically identified; thus, expert opinion is not required,” it furthered.

Follow Tan Briones & Associates on LinkedIn for more legal updates and law-related articles.