25/05/2026
For us to know.
SUPREME COURT NULLIFIES MARRIAGE OVER HUSBAND’S ABUSIVE, IRRESPONSIBLE BEHAVIOR
The Supreme Court (SC) has upheld the ruling of the Court of Appeals (CA) declaring a marriage void on the ground of the husband’s psychological incapacity, citing his abusive and possessive behavior toward his wife, coupled with his lack of direction and ambition in life.
In a 29-page decision authored by Associate Justice Maria Filomena Singh, the SC's Third Division has declared void from the beginning the marriage of a couple on the ground of the husband's psychological incapacity as provided under Article 36 of the Family Code.
The couple first met in 2010, when the husband obtained the wife’s cellphone number and began courting her through text messages the following day. At first, the wife did not take his messages seriously, but his persistent personal visits eventually led to them officially becoming a couple four months later.
After a month of dating, the wife observed that the husband lacked direction and ambition. He spent most of his time with peers, indulging in various vices. Despite having practical skills in electricity, he resisted seeking employment in his early twenties, claiming that work would interfere with his social life.
Additionally, he began requesting money from the wife to support his habits. Further, he was highly jealous and possessive, forbidding the wife from interacting with anyone, including female friends. He stalked her and threatened to harm anyone who interfered with their relationship.
Due to these reasons, the wife attempted to break up with him, but he threatened su***de if she ended the relationship. Fearing for her well-being, the wife reluctantly stayed. The wife eventually came to love the husband and became pregnant. Upon learning of the pregnancy, the husband reacted angrily and insisted on abortion. The wife opposed the idea and sought the support of their parents, who convinced him to marry her.
They eventually get married in 2012. Three weeks after the wedding, the husband disappeared for three days. When he returned, the wife asked where he had been and expressed concern for his well-being. Instead of apologizing, he told her not to worry if he was with his friends, as they were more important than her. He further claimed that she had forced him into marriage and that she alone wanted the child.
The husband's behavior persisted throughout the marriage. He frequently went on drinking binges with peers, leaving the wife behind without financial support or knowledge of his whereabouts. When criticized, he responded violently, even throwing kitchenware during one argument. His addictions to cockfighting, alcohol, and gambling further strained the relationship.
Three months into the marriage, the wife discovered that the husband had rekindled a relationship with his ex-girlfriend. When confronted, he admitted the affair, claiming the ex-girlfriend provided joy that the wife could not. This led to their separation, but with parental intervention, they reconciled, and the husband promised to change.
The wife gave birth to their son, but despite this, the husband became more apathetic and indifferent, remaining insensitive to his family's needs. When she urged him to find work due to their growing financial pressures, he responded with anger.
Consequently, the wife took on the sole responsibility of supporting the family. She was eventually forced to quit after the husband publicly slapped her for refusing to give him money for his vices, subjecting her to public humiliation.
The wife later went to Hong Kong in 2013 to work as a domestic helper, leaving their child in the care of her mother. During this time, the husband neither visited their child nor provided any support. Eventually, the wife learned that the husband was cohabiting with another woman and had fathered an illegitimate child.
This prompted her to file a petition for nullification of marriage on the ground of the husband's inability to fulfill his essential marital duties and her inability to tolerate his abusive behavior any longer.
The Regional Trial Court (RTC) dismissed her petition, noting that she presented no supporting evidence pertaining to the portrayed behavior of the husband as a drunkard, womanizer, gambler, physical and sexual abuser, drug addict, and drug pusher.
It noted that these allegations appear to be exaggerated in casting all sorts of vices and bad behavior upon the husband, none of which was substantiated by clear and convincing evidence other than the bare allegations of the persons who, obviously, are in favor of the dissolution of the couple's marriage.
The Court of Appeals reversed the decision of the RTC and declared their marriage void ab initio. The Office of the Solicitor General representing the Republic eventually elevated the case before the Supreme Court.
In affirming the appellate court's ruling, the high court rejected the arguments of the OSG, saying there was collusion that existed between the parties due to the husband's knowledge that his father had served as a witness to the wife's petition.
The SC held that there is no evidence of collusion between the wife and husband. It noted that the testimonies of the husband's father and cousin, who witnessed his childhood, should be given credence in determining his psychological incapacity.
"The husband's father and cousin testified that the breakdown of the marriage between the wife and husband stemmed from his long-standing behavioral issues and vices, which had been evident long before he ever met the wife," the Supreme Court said.
It emphasized that the concept of juridical antecedence necessary for nullification of marriage includes the ordinary experiences of the spouses not only prior to the marriage itself but, more importantly, during their "lived conjugal life." Here, the wife testified that he was a jealous and possessive partner who stalked her and threatened to kill anyone who came between them. He lacked direction, spent most of his time drinking with friends, and showed no improvement after marriage.
It also gave credence to the Psychological Evaluation Report, which revealed that the husband is suffering from three personality disorders: (1) Narcissistic Personality Disorder; (2) Antisocial Personality Disorder; and (3) Histrionic Personality Disorder.
The highest bench underscored that the gravity of the husband's incapacity was proven as the he consistently failed to provide the wife with any form of emotional support or affection. He demonstrated persistent financial irresponsibility, prioritizing personal vices over the welfare of his family.
