The Supreme Court has affirmed that testimonies from a spouse’s family members and close friends may be considered in establishing psychological incapacity in petitions to declare a marriage null and void.

In a decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the Court’s Second Division upheld the nullity of the marriage between Jeffery A. Green and Rowena Manlutac Green on the grounds of Rowena’s psychological incapacity.

The couple had been in a relationship for four years before marrying. Another four years later, Jeffery filed for nullity of marriage, claiming that both parties were psychologically incapacitated. He submitted a psychiatric evaluation that relied on standardized tests and interviews with himself, Rowena, a mutual friend, and Rowena’s mother.

The evaluation detailed Rowena’s persistent mismanagement of finances, including debts amounting to PHP 4 million. It also cited allegations of infidelity and dishonesty regarding the paternity of their child.

The Regional Trial Court granted the petition, declaring Rowena psychologically incapacitated to fulfill her marital obligations. This ruling was affirmed by both the Court of Appeals and the Supreme Court.

In its decision, the High Court emphasized that in cases involving psychological incapacity, the testimony of individuals close to the allegedly incapacitated spouse may provide valuable insight. Such testimonies help mitigate potential bias from the petitioning spouse.

“This is a realistic reception of psychological assessments,” the Court explained, noting that close relatives or friends of the allegedly incapacitated spouse are not likely to give hostile or untruthful testimonies—unless proven otherwise.

The Supreme Court reiterated that a marriage may be declared null under Article 36 of the Family Code if the totality of evidence establishes that psychological incapacity existed at the time of marriage.

In support of his petition, Jeffery submitted documents showing Rowena’s gambling problems, dishonesty, and infidelity. These, along with the psychiatric report, led to a diagnosis of Borderline Personality Disorder and Antisocial Personality Disorder—conditions described as incurable and rooted in early childhood trauma. The Court concluded that these disorders rendered her incapable of fulfilling basic marital obligations.

Citing the findings, the Court noted: “Her unstable interpersonal relationships, distorted self-image and emotions, impulsivity, deceitfulness, irresponsibility, and lack of remorse resulted to (her refusal) to live with Jeffery, they had no fixed family domicile, she lied about (their daughter”s) paternity, she was a gambler and a spendthrift but was entirely dependent on Jeffery’s support , and she made one lie after another and got deeper and deeper in debt, resulting in civil and criminal cases,” said the court.