Facts
Arnold and Michelle got married after the latter became unexpectedly pregnant.
Shortly after the wedding, Michelle exhibited behaviors that Arnold claimed made their marital life impossible. She lived a luxurious lifestyle beyond their means, incurring millions in debt that Arnold’s father eventually had to pay. She allegedly fabricated lies to secure loans and compelled Arnold to issue checks that led to the bankruptcy of his business. She refused to perform household chores, was verbally aggressive, and eventually eloped with another man in 2010, abandoning Arnold and their three children.
Arnold filed for the declaration of nullity of marriage. The RTC granted the Petition. The Republic of the Philippines, through the OSG, appealed the RTC Decision. The CA rendered a Decision reversing the RTC Decision, granting the OSG’s appeal.
ISSUE: Whether Michelle’s behavior constituted “psychological incapacity” grave enough to nullify the marriage.
Ruling
The Supreme Court granted the petition and reinstated the RTC decision, declaring the marriage null and void.
The Court found that Michelle suffered from Histrionic and Antisocial Personality Disorders. Her behavior was not just bad habits, but was rooted in a durable personality structure that existed before the marriage. Her pattern of deceit, financial recklessness, and eventual abandonment of her children demonstrated a total inability to understand and comply with the essential marital obligations of mutual love, respect, and support.
Reiterating the Tan-Andal case, the Court clarified that while a clinical diagnosis like Histrionic PD is helpful, the focus is on the totality of evidence showing a persistent, gravity-laden inability to function as a spouse.
As recognized under Article 1 of the Family Code, in every marriage lies the vinculum juris – the juridical bond that unites the spouses in a legally and morally binding union governed by law. This vinculum juris imposes upon each spouse the essential marital obligations of mutual love, respect, fidelity, and support. When it becomes manifest that one party is psychologically incapacitated to assume these duties, the very foundation of that bond is rendered void.