MANILA — The Supreme Court (SC) has affirmed the Court of Appeals’ ruling nullifying a marriage on the ground of the wife’s psychological incapacity, citing her domineering and controlling behavior, including demanding that her husband always update her on his whereabouts.

In a 14-page decision penned by Associate Justice Henri Jean Paul Inting, the SC’s Third Division declared the marriage void from the beginning under Article 36 of the Family Code.

The couple, married on January 22, 1995, had no antenuptial agreement, and their property relations were governed by the regime of absolute community of property.

The husband testified that the wife’s psychological incapacity was evident even before their wedding, marked by her domineering attitude and poor study habits. He added that her incapacity worsened after marriage, including physically attacking him in the presence of their children and sneaking into his mother’s house to take the kids without notice.

A clinical psychologist diagnosed the wife with Narcissistic Personality Disorder with paranoid features, describing the condition as grave, incurable, and with antecedents, and recommended the nullification of their marriage.

The wife, in her defense, alleged that her husband abused their children both psychologically and sexually, and physically and verbally abused her during disagreements.

Both the Regional Trial Court and the Court of Appeals had granted the nullification petition, giving weight to psychological reports confirming the wife’s incapacity as grave and incurable. The SC found no reason to overturn these findings.

The high court cited the landmark case of Tan-Andal vs. Andal, emphasizing that psychological incapacity must be grave enough to prevent a spouse from fulfilling essential marital obligations, and must exist prior to or at the time of marriage.

The SC ruled that the husband’s evidence, corroborated by witness accounts and the psychologist’s testimony, sufficiently established the wife’s narcissistic personality disorder with paranoid features. It also noted that her incapacity affected all areas of her life, rendering her unable to perform essential marital duties.

With the marriage declared void, the SC remanded the case to the trial court to address issues regarding the liquidation, partition, and distribution of the couple’s common properties under Article 147 of the Family Code.