The Supreme Court (SC) has reaffirmed that psychological incapacity under Article 36 of the Family Code must be proven by clear and convincing evidence of a spouse’s inability to fulfill the essential obligations of marriage, and that a spouse’s failure to oppose a petition does not, by itself, establish collusion.

In a decision penned by Associate Justice Maria Filomena D. Singh, the SC denied the Republic’s petition and affirmed the Court of Appeals’ ruling declaring the marriage between Ma. Theresa Ramoran-Wong and Vincent L. Wong void ab initio under Article 36 of the Family Code.

“Given the totality of evidence, the Court finds no reason to overturn the CA Decision finding Vincent psychologically incapacitated to fulfill his essential marital obligations to Theresa. Consequently, their marriage is void under Article 36 of the Family Code,” the SC wrote.

FACTS AND ISSUE

The case stemmed from Theresa’s petition to declare her marriage to Vincent void on the ground of psychological incapacity.

She alleged that Vincent displayed persistent irresponsibility, emotional neglect, financial abuse, infidelity, and violent behavior before and during their marriage. To support her petition, she presented testimonies from relatives and a psychologist who concluded that Vincent suffered from personality disorders that rendered him incapable of performing the essential obligations of marriage.

The Regional Trial Court dismissed the petition, finding the evidence insufficient to establish psychological incapacity. On appeal, however, the Court of Appeals reversed the ruling, holding that Theresa had proven through clear and convincing evidence that Vincent’s condition satisfied the requisites for psychological incapacity and declaring the marriage void ab initio.

Before the SC, the Republic, through the Office of the Solicitor General, argued that the spouses had colluded to obtain a declaration of nullity and that Theresa failed to prove Vincent’s psychological incapacity by clear and convincing evidence.

RULING

The SC denied the Republic’s petition and affirmed the appellate court’s decision.

It ruled that the allegation of collusion was unsupported, noting that the investigating prosecutor had found none and that Vincent’s failure to oppose the petition did not, by itself, establish collusion.

The SC further held that the evidence established Vincent’s inability to fulfill the essential obligations of marriage. Citing the standard in Tan-Andal v. Andal, it reiterated that psychological incapacity is a legal concept that must be proven by clear and convincing evidence and may be established through lay witnesses, with expert testimony no longer indispensable.

It found that Vincent’s repeated emotional neglect, financial irresponsibility, violence, infidelity, and failure to support his family demonstrated the gravity, juridical antecedence, and incurability required under Article 36 of the Family Code.

“Marriage, in its truest form, must be a sanctuary: a space of mutual respect, care, and emotional safety. It must never become a chain that binds a person to a relationship that is not only fundamentally flawed, but damaging,” the SC said.

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