Inability to love from personality disorder may be considered ground for annulment—SC
The Supreme Court ruled that one’s inability to love their spouse because of a personality disorder may be considered a ground to void their marriage.
In a 16-page decision written by Senior Associate Justice Marvic Leonen, the SC's Second Division pointed out that it’s possible for a spouse’s psychological incapacity to manifest “long after the solemnization of a marriage.”
“A spouse who previously seemed capable of performing his marital obligations may prove to be incapable of doing so, and the marriage must be voided so long as the incapacity is shown to be due to a genuine psychic cause,” it added.
The high court reinstated a previous ruling by the regional trial court that nullified a marriage from the beginning as the husband wasn't able to fulfill his marital duties due to his psychological incapacity.
The couple met in 1999 and tied the knot in 2002, though they had only been physically together for five years as the husband needed to work in another country. Per the SC, their relationship "was marked by frequent arguments and periods of separation."
The husband filed a petition to void their union in 2016, which he backed with his Passive-Aggressive Personality Disorder diagnosis. According to health information website Mayo Clinic, the condition involves a "pattern of indirectly expressing negative feelings instead of openly addressing them."
His petition was initially granted by the RTC but was later reversed on reconsideration. His appeal was rejected by the Court of Appeals.
The SC ruled that the husband was able to provide sufficient evidence for his psychological incapacity. It found that "the husband no longer loved his wife, and that this inability to love her is rooted in his personality, caused by an emotionally immature parent."
The high court pointed out that the husband may have been able to provide financial support to his family, but he wasn't able to meet his partner's emotional needs.
"Loving one’s spouse is an important, if not the most important, essential marital obligation," the SC noted, adding that the petitioner "must not be forced to stay in a loveless marriage, and his marriage to private respondent must be voided."
