MANILA, Philippines — The Supreme Court (SC) has reaffirmed that testimonies from the family and friends of a spouse can be used to prove psychological incapacity in petitions to nullify a marriage.

In a decision penned 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.

According to court documents, Jeffery and Rowena had been in a relationship for four years before getting married. Another four years into their marriage, Jeffery filed a petition to nullify their union, claiming both he and Rowena were psychologically incapacitated.

To support his petition, Jeffery submitted a psychiatric evaluation based on standard tests and interviews involving himself, Rowena, a mutual friend, and Rowena’s mother.

The psychiatric report detailed Rowena’s alleged mismanagement of their finances, including incurring debts of up to P4 million. It also accused her of infidelity and dishonesty, including lying about the paternity of their child.

The Regional Trial Court (RTC) granted Jeffery’s petition, ruling that Rowena was psychologically incapacitated to perform her essential marital obligations. The Court of Appeals affirmed the RTC’s decision, which the Supreme Court upheld.

In its ruling, the SC stressed that psychological incapacity may be established through testimonies from people other than the spouses, particularly those close to the allegedly incapacitated party. This, it said, helps avoid potential bias in relying solely on the account of the petitioning spouse.

“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,” the Court said. It added that unless these testimonies are falsified to favor the petitioning spouse, they should be considered.

The SC said that as long as the totality of evidence proves psychological incapacity at the time the marriage was celebrated, the marriage may be nullified under Article 36 of the Family Code.

In this case, Jeffery’s evidence included documentation of Rowena’s debts, gambling history, dishonesty, and infidelity. These were supported by the psychiatric evaluation report based on interviews and standard tests.

The evaluation diagnosed Rowena with Borderline Personality Disorder and Antisocial Personality Disorder, which were found to be deeply rooted and incurable. The Court said these disorders prevented her from fulfilling her marital duties.

“Her unstable interpersonal relationship, self-image and emotions, impulsivity, deceitfulness, consistent irresponsibility, and lack of remorse resulted to ‘[her refusal] to live with Jeffery, they have 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,’” the SC said.