The testimonies of family and friends can play a key role in proving psychological incapacity in marriage annulment cases, the Supreme Court (SC) reaffirmed recently.

In a ruling penned by Senior Associate Justice Marvic M.V.F. Leonen dated 17 February, 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.

Jeffery and Rowena were together for four years before getting married. But four years into the marriage, Jeffery filed a petition to nullify it, claiming that both he and Rowena were psychologically unfit for marriage.

To back his claim, Jeffery submitted a psychiatric evaluation based on standard tests and interviews of himself, Rowena, Rowena’s mother and a mutual friend.

The report detailed how Rowena repeatedly mismanaged their finances, racking up debts of up to P4 million. She was also accused of infidelity and lying about the paternity of their child.

The Regional Trial Court granted the annulment, ruling that Rowena was psychologically incapacitated to fulfill her marital duties — a decision later upheld by both the Court of Appeals and the SC.

The SC emphasized that in cases like this, testimonies from people close to the allegedly incapacitated spouse — like family and friends — are especially valuable. This helps reduce the risk of bias that might come from the spouse filing the petition.

“This is a practical approach to psychological assessments, as friends and relatives of the alleged incapacitated spouse are generally less likely to give hostile or biased testimony,” the Court noted. Unless those testimonies are proven false, they should be seriously considered, it added.

The SC reiterated that as long as the total evidence shows a spouse was psychologically incapacitated at the time of the marriage, the union can be nullified under Article 36 of the Family Code.

Jeffery presented documents detailing Rowena’s debts, gambling habit, dishonesty, and infidelity. These were backed by a psychiatric report diagnosing her with Borderline Personality Disorder and Antisocial Personality Disorder — conditions rooted in deep-seated trust issues dating back to her childhood.

The disorders, the Court said, made Rowena incapable of meeting her marital obligations.