Reasonable expectations of boundaries are expected in any relationship. And necessarily, it comes with a series of arguments, clarifications, and discussions, possibly heated sometimes, from both partners to understand, compromise, and come to terms with a setup that works for each other. However, not all relationships work like that, especially when it comes to what society may deem ‘toxic’ behaviors exacerbated by mental health problems.
In the case here in the Philippines, the Supreme Court (G.R. No. 259322) ruled a marriage void ab initio or void from the beginning for a spouse’s (petitioner) “controlling” and “domineering” behavior, assessed to be due to a Narcissistic Personality Disorder (NPD) with paranoid features.
The case of a void marriage due to psychological incapacity
In the decision dated November 3, 2016, the respondent (then petitioner) cited many instances, including:
- petitioner’s continued domineering and controlling behavior, demanding that the respondent always update her on his whereabouts
- petitioner’s arrogant and haughty attitude, especially towards the respondent’s mother, as well as an excessive sense of entitlement
- irrationally insisted that the respondent was having an incestuous relationship with his mother
- verbally abused the respondent whenever the latter brought their children to visit his side of the family
- tried to deliberately alienate their son from their paternal grandmother
- physically attacked him in the presence of their kids, while he was holding their daughter
- did not invite any of his relatives, except for one cousin, to their son’s seventh birthday
- taught the kids to say bad things about his mother
- sneaked into his mother’s house to take the kids home without telling anyone
- without his consent and through intimidation, entered his place of employment and forcibly took documents, records, and other articles of value
Various witnesses corroborated the fact that she was psychologically incapacitated to comply with her essential marital obligations. And later, even their daughter who was her own witness, corroborated the fact that she completely disregarded lawful court orders.
The clinical psychologist diagnosed her with NPD with paranoid features, and that this psychological incapacity was grave, incurable, and had antecedents, and thus, recommended the termination of the parties’ marriage.
The RTC granted his petition and declared the marriage between the parties void on the ground of his spouse’s psychological incapacity under Article 36 of the Family Code.
The petitioner filed for reconsideration, which the RTC denied on May 4, 2017, for lack of merit. Then, she elevated the case via an ordinary appeal with the Court of Appeals (CA) in 2021. The CA only affirmed the RTC decision and order in toto (entirely).
While she argued for many allegations in this petition, ultimately saying that the RTC erred in granting the petition in 2017 and the CA in affirming the Resolution in 2021, the Court once again denied her petition for lack of merit, as discussed below.
First, she argued for the erroneous decision to uphold the declaration of nullity of her marriage with the respondent based on the psychological report about her even though the psychologist never personally examined her.
The Court rejected the argument that the absence of a personal psychological examination rendered the diagnosis invalid. Citing established jurisprudence, it ruled that personal examination of the respondent spouse is not an indispensable requirement in petitions under Article 36. What is controlling is whether the expert opinion is supported by credible testimony, corroborative evidence, and the surrounding circumstances, all of which were present in this case
Second, the CA completely disregarded Nellie’s narration of facts in relation to the physical, sexual, emotional, financial, and psychological abuse that she suffered at his hands. It also erred in not ruling that his acts against her were tantamount to contracting marriage in bad faith. And in connection, third, assuming arguendo that the marriage is void, the CA erroneously ruled that he is not psychologically incapacitated to perform his marital obligations to her.
The Court found no merit in this. Even for the sake of argument that the allegations were true and that he was psychologically incapacitated himself, that does not cancel out the factual and consistent findings of the Courts against her psychological incapacity.
In sum, the Court found that the Decisions and Resolutions correctly appreciated the evidence, properly applied the standards for psychological incapacity, and committed no reversible error, affirming in toto the RTC’s decision declaring the marriage void ab initio under Article 36 of the Family Code.
In conclusion
This case reinforces that toxic and controlling behavior rooted in a clinically established personality disorder may rise to the level of psychological incapacity when it renders a spouse genuinely incapable of fulfilling the essential obligations of marriage. It also affirms the Court’s evolving, more realistic approach in assessing psychological incapacity—one that looks beyond labels and focuses on actual marital dysfunction and its impact on the relationship and the family life.
Marriage, while demanding patience and compromise, does not require a spouse to endure a relationship marked by domination, paranoia, and psychological harm. Where the law recognizes that the foundation was broken from the very beginning, it provides relief—not punishment—by declaring the marriage void from the start.
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Author/s: Patricia Minimo
About the author(s): Patricia is STLAF's Legal Writer-Researcher. She is a Communication graduate from the University of the Philippines – Baguio with a major in Journalism and a minor in Speech Communication.