A spouse’s inability to love or emotionally connect—when rooted in a genuine personality disorder—may be considered psychological incapacity and used as legal grounds to declare a marriage void, the Supreme Court has ruled.
In a decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the Supreme Court’s Second Division reinstated an earlier ruling of the Regional Trial Court (RTC), which declared a marriage void from the beginning due to the husband's psychological incapacity to fulfill marital obligations.
The couple met in 1999 and married in secret in 2002. They didn’t immediately live together, as the husband worked in Saudi Arabia. During a brief visit in 2004, they held a church wedding, after which the husband returned abroad.
When he came back to the Philippines in 2005, they lived together intermittently and had two children: a son in 2007 and a daughter in 2012. Over the years, however, their time together totaled only about five years, marred by frequent arguments and separations.
In 2016, the husband petitioned for the nullity of their marriage, supported by a psychologist’s diagnosis that he had Passive-Aggressive Personality Disorder—an illness marked by emotional detachment and difficulty maintaining close relationships.
While the RTC initially granted the petition, it reversed its decision following due process concerns raised by the Office of the Solicitor General. The Court of Appeals later dismissed the husband's appeal.
But the Supreme Court sided with the husband, affirming that his psychological incapacity had been sufficiently proven.
Under Article 36 of the Family Code, a marriage may be declared void if one or both spouses are psychologically incapable of fulfilling essential marital obligations—even if such incapacity emerges only after the wedding.
The court clarified that this incapacity must be deeply rooted in a person’s character and must have existed before the marriage. It emphasized that psychological incapacity may not be immediately visible and may surface only later in the relationship.
In this case, the Court said the husband's inability to emotionally connect stemmed from an upbringing marked by strictness and emotional immaturity from his parents. While he fulfilled his role as a financial provider, he could not meet his wife’s emotional needs, including companionship.
The Court stressed that, “Loving one’s spouse is an important, if not the most important, essential marital obligation.” It concluded that the husband’s inability to love his wife was caused by his psychological condition and that he should “not be forced to stay in a loveless marriage.”