Psychological incapacity kills young love

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Aboy and a girl in their college days met at a Filipino-Chinese mixer. Within three months they fell in love and eloped to Cebu. Initially, the boy was hesitant about eloping because he had no job and was worried about how he could support themselves, but after much convincing from his girlfriend, he agreed.

To their dismay, the couple could not find any job and their savings only lasted one month. Without any other option, they returned to Manila to live with the boy’s parents.

Unfortunately, they found out that the boy’s parents were abroad when they arrived in Manila. So the girl lived in her uncle’s house. She wanted the boy to live with her at her uncle’s and threatened to commit suicide if he did not. He, of course, obliged. Within two months, they got married. He was 25. She, 20.

The young husband’s desire to live in his parents house continued while he was living at the uncle’s house because they would not let him see his family and the uncle continuously threatened him by showing him his gun collection. When he brought it up to his wife, she suggested that he ask for his inheritance instead so they could finally live on their own. The young husband’s father refused to give him his inheritance. After learning that her husband would not get his inheritance, the wife suggested that they live separate lives.

The husband filed a petition to nullify his marriage based on psychological incapacity. He and his wife were examined by a clinical psychologist, who found both spouses “emotionally immature and recklessly impulsive.” Thus, the Regional Trial Court declared the marriage null and void on the ground that both spouses were psychologically incapable of complying with the essential marital obligations. The Court of Appeals (CA), however, reversed the decision of the trial court because the trial court did not personally examine the wife, thus, failing to prove her psychological incapacity.

The Supreme Court (SC) reversed the CA based on the doctrine that findings of the trial court are final and binding on the appellate courts –
… Each case must be judged according to its own facts. In the field of psychological incapacity as a ground for annulment of marriage, it is trite to say that no case is on ‘all fours’ with another case. The trial judge must take pains in examining the factual milieu and the appellate court must, as much as possible, avoid substituting its own judgment for that of the trial court.

In fact, there is no requirement that the person declared psychologically incapacitated must be personally examined by a physician, if the totality of evidence presented is enough to sustain a finding of psychological incapacity. Since annulment cases on psychological incapacity are decided on a case-to-case basis, they should be “guided by experience, the findings of experts and researchers in psychological disciplines, and by decisions of church tribunals.” Expert opinions of clinical psychologists on the psychological and mental temperaments of the parties, for example, must be given great weight.

Lastly, the SC stressed that despite dissolving marriages on account of psychological incapacity, the “Court is not demolishing the foundation of families, but it is actually protecting the sanctity of marriage, because it refuses to allow a person afflicted with a psychological disorder, who cannot comply with or assume the essential marital obligations, from remaining in that sacred bond.” In Article 36, there is no marriage to speak of in the first place, as the same is void from the very beginning. The declaration of nullity will simply provide a decent burial to a stillborn marriage (Te v. Yu-Te, G.R. No. 161793, 13 February 2009, J. Nachura).

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