The Supreme Court of the Philippines has significantly altered the landscape of marriage nullity by revisiting the interpretation of psychological incapacity under Article 36 of the Family Code. Departing from a rigid, medically-focused approach, the Court now emphasizes a more nuanced, case-specific analysis, focusing on the genuine inability of a spouse to fulfill essential marital obligations. This landmark decision aims to uphold individual liberty and human dignity, paving the way for a more humane and realistic assessment of marital dysfunction.

From Sickness to Structures: Can a Marriage Survive Incompatible Personalities?

The case of Rosanna L. Tan-Andal v. Mario Victor M. Andal involves a couple whose marriage deteriorated due to the husband’s drug abuse, financial irresponsibility, and emotional immaturity. Rosanna sought to nullify their marriage based on Mario’s psychological incapacity, presenting psychiatric evidence of his narcissistic antisocial personality disorder. While the trial court initially granted the petition, the Court of Appeals reversed, deeming the psychiatric evaluation unreliable. This prompted Rosanna to elevate the case to the Supreme Court, raising critical questions about the interpretation and application of Article 36 of the Family Code.

At the heart of the Supreme Court’s analysis lies a re-evaluation of the guidelines set forth in Republic v. Court of Appeals and Molina, which had long governed the interpretation of psychological incapacity. These guidelines, while intended to prevent frivolous petitions, had inadvertently imposed a rigid framework, often requiring medical or clinical proof of a specific psychological illness. The Court recognized that this approach had become overly restrictive, failing to capture the true essence of psychological incapacity as envisioned by the framers of the Family Code.

The Supreme Court emphasized that psychological incapacity is a legal, not strictly a medical, concept. While medical or psychological evaluations can provide valuable insights, they are not indispensable. The crucial question is whether a spouse’s personality structure renders them genuinely incapable of understanding and fulfilling the essential marital obligations, which include mutual love, respect, fidelity, support, and the responsibilities of parenthood. This incapacity must be grave, existing at the time of the marriage, and, in a legal sense, incurable, meaning it is so enduring and persistent with respect to a specific partner that the marriage’s breakdown is inevitable.

Notably, this interpretation shifts the focus from labeling a spouse with a specific mental disorder to examining the dynamics of the relationship and the individual’s ability to function within the marriage. The Court clarified that drug addiction, infidelity, or emotional immaturity, while potentially grounds for legal separation, do not automatically equate to psychological incapacity. Instead, these behaviors must be manifestations of a deeper, more fundamental inability to comprehend and comply with marital obligations.

To prove psychological incapacity, the Court now requires clear and convincing evidence, a higher standard than mere preponderance. This evidence may include testimonies from ordinary witnesses who have observed the spouse’s behavior, expert opinions, and any other relevant information that sheds light on the individual’s personality structure and capacity for marital commitment. The Court stressed that each case must be judged on its own merits, free from rigid assumptions and generalizations.

The Supreme Court’s decision also addressed the issue of property relations in cases of void marriages. It affirmed that Article 147 of the Family Code governs the division of properties acquired during cohabitation, ensuring that each party receives a fair share based on their contribution to the union. Moreover, the Court upheld the award of custody of the parties’ child to Rosanna, recognizing her greater care and devotion.

This ruling marks a significant step towards a more humane and realistic approach to Article 36, acknowledging the complexities of human relationships and the importance of individual autonomy. By emphasizing the need for a case-specific analysis and de-emphasizing the rigid medical requirements, the Supreme Court has paved the way for a more just and equitable resolution of marital disputes, ensuring that individuals are not trapped in unions that are fundamentally incompatible with their well-being.

The Supreme Court has clarified that while the interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church of the Philippines should be given great respect by our courts, canonical decisions are, to reiterate, merely persuasive and not binding on secular courts. Canonical decisions are to only serve as evidence of the nullity of the secular marriage, but ultimately, the elements of declaration of nullity under Article 36 must still be weighed by the judge.

What was the key issue in this case?	The key issue was whether the marriage between Rosanna and Mario was void due to Mario’s psychological incapacity, and whether the guidelines in Republic v. Molina were overly restrictive.
What is psychological incapacity under Philippine law?	Under Article 36 of the Family Code, it’s the inability to comply with essential marital obligations due to causes of a psychological nature, existing at the time of the marriage.
What did the Supreme Court change about proving psychological incapacity?	The Court de-emphasized the need for medical evidence and expert testimony, focusing instead on the totality of evidence and the spouse’s ability to function within the marriage.
Is a psychiatric evaluation still required to prove psychological incapacity?	No, a psychiatric evaluation is no longer mandatory; courts can now rely on testimonies and other evidence to determine if a spouse is psychologically incapacitated.
What quantum of proof is required in proving psychological incapacity?	The new quantum of proof is “clear and convincing evidence,” a higher standard than preponderance of evidence, reflecting the inviolability of marriage.
Does this ruling mean it’s easier to get a marriage annulled now?	While medical proof is not mandatory, it is still required to present a high degree of believability to establish the existence of a spouse’s psychological incapacity.
What happens to properties if a marriage is declared void due to psychological incapacity?	The property regime of parties to a void marriage is governed by Article 147 or Article 148 of the Family Code, depending on their capacity to marry.
What does this ruling mean for couples seeking to end their marriage?	Couples can now present a broader range of evidence, focusing on the spouse’s behavior and inability to fulfill marital obligations, rather than solely relying on medical diagnoses.

This landmark decision represents a significant shift in the legal understanding of marriage and psychological incapacity in the Philippines. By prioritizing individual liberty and human dignity, the Supreme Court has opened the door for a more compassionate and nuanced approach to marital disputes. This ruling encourages a deeper examination of the relational dynamics between couples, recognizing that the true essence of marriage lies in the ability to fulfill its essential obligations with love, respect, and understanding.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Tan-Andal v. Andal, G.R. No. 196359, May 11, 2021