SC rules on testimonies in marriage nullity cases
THE Supreme Court has reaffirmed that testimonies from a spouse’s family and friends can help prove psychological incapacity in cases seeking to nullify a marriage.
In a decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC’s Second Division declared the marriage of Jeffery A. Green and Rowena Manlutac Green null and void due to Rowena’s psychological incapacity.
Jeffery and Rowena were in a relationship for four years before marrying.
Another four years later, Jeffrey filed a petition to nullify their marriage, claiming that both he and Rowena were psychologically incapacitated.
As evidence, Jeffrey 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 frequently mismanaged their finances, accumulating debts of up to P4 million.
She was also accused of cheating on Jeffrey and lying about the paternity of their child.
The Regional Trial Court (RTC) granted the petition, declaring Rowena psychologically incapacitated to fulfill her marital duties.
The Court of Appeals and the SC upheld the RTC’s ruling.
The SC emphasized that in nullity of marriage cases, psychological incapacity can be evaluated using statements from people other than the spouses, especially from those close to the allegedly incapacitated spouse.
This approach helps avoid potential bias from the spouse who filed the petition.
“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.”
Unless these testimonies are falsified to favor the petitioning spouse, they should be considered.
The SC reiterated that so long as the totality of the evidence can prove a spouse’s psychological incapacity at the time the marriage was celebrated, the marriage can be nullified under Article 36 of the Family Code.
In this case, Jeffery presented documentary evidence on Rowena’s debt and gambling history, dishonesty, and infidelity.
These were supported by the psychiatric evaluation report based on standard tests and interviews with the couple, a mutual friend, and Rowena’s mother.
All of these show Rowena suffers from continuing and incurable Borderline Personality Disorder and Antisocial Personality Disorder, which stem from trust issues that began in her childhood.
