THE FLAME THAT LOST ITS NAME: Court's Position on Spouse's Neglect of Marital Duties

"I gave you everything, but you left me with nothing." - Nino portrayed by Gerald Anderson, How To Be Yours

In the world of Filipino television and cinema, we are all familiar with the dramatic rise and fall of relationships. From clandestine affairs to heartbreaking betrayals, these narratives often mirror the painful reality faced by many couples. We witness characters grappling with infidelity, emotional neglect, and a slow, agonizing drift into estrangement. These on-screen dramas, while entertaining, also serve as a poignant reminder that the vows made at the altar are not always enough to sustain a marriage.

The law, however, provides a way out for those trapped in a union that has lost its foundation. This is where psychological incapacity comes into play — a concept our highest court has clarified and expanded as a basis for declaring a marriage void from its inception.

Heart of the Matter

In certain instances, the law allows for the dissolution of marital bonds when a spouse is psychologically incapable of fulfilling their essential marital obligations. This is governed by Article 36 of the Family Code, which states:

"A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization."

The Supreme Court has further refined the application of this law over the years. In the landmark case of Tan-Andal v. Andal (G.R. No. 196359), the court emphasized that psychological incapacity is not merely a mental illness but a personality disorder that makes it impossible for a person to understand and comply with their marital obligations. The court also clarified that expert opinion is not always necessary to prove this. Ordinary witnesses can testify to consistent behaviors that show a spouse's dysfunctionality.

In another important case, Candelario v. Candelario (G.R. No. 222068), the Court established a three-part test for psychological incapacity. This includes gravity, which means the incapacity must be serious enough to prevent the fulfillment of marital duties. Next is incurability, which is understood in a legal sense, meaning the spouses' personality structures are so incompatible that their marriage is bound to fail. Lastly, juridical antecedence requires the condition to have existed before the marriage was celebrated, even if it only becomes apparent later on.

The Long Burn

The case of Arnold Alfonso v. Michelle Pamintuan-Alfonso perfectly illustrates how these legal principles are applied in a real-world scenario. In a decision penned by Associate Justice Samuel Gaerlan, the Supreme Court's Third Division tackled a narrative that reads like a screenplay. Arnold and Michelle, who were high school classmates, reconnected years later. Their relationship, which began while Michelle was still with another man, led to an unplanned pregnancy. Arnold convinced Michelle not to have an abortion and offered to marry her. They eventually had three children and lived in Arnold’s family home.

A year into their marriage, their relationship began to sour. Arnold noticed that Michelle was verbally aggressive towards him and refused to do household chores or care for their children. She also accumulated immense debt due to her luxurious lifestyle. Over time, Michelle's behavior grew colder, and she refused to fulfill her sexual obligations. In 2010, Arnold discovered that Michelle was having an affair and had cut off all communication with him and their children.

This series of events led Arnold to file a petition for the nullification of their marriage on the ground of Michelle's psychological incapacity. The Regional Trial Court (RTC) initially granted the petition and nullified their marriage, but the Court of Appeals (CA) later reversed the ruling. This prompted Arnold to elevate the case to the Supreme Court.

In granting Arnold's petition, the Court held that he was able to illustrate that Michelle's incapacity was so grave or serious that it already impaired her ability to carry out the required ordinary marital duties. The Court gave credence to the psychological report, which diagnosed Michelle with histrionic personality disorder and antisocial personality disorder. The SC also emphasized that the incapacity of Michelle was incurable, as the pattern of persistent failure to assume her essential marital obligations was proven. It also took into account the instance where Michelle entered into an illicit affair with another man, which the Court viewed as a manifestation of her inability to respect her marital vows.

The Supreme Court’s decision reiterates the very foundation of a marital union. "In every marriage lies the vinculum juris — the juridical bond that unites the spouses in a legally and morally binding union governed by law. This vinculum juris imposes upon each spouse the essential marital obligations of mutual love, respect, fidelity, and support," the Court said. "Thus, in the present case, we hold that Michelle's psychological incapacity existed prior to and during the celebration of the marriage; the vinculum juris is deemed never to have validly arisen," it added.

A Way to Heal and Move Forward

This new jurisprudence from the Supreme Court sets forth a significant development for cases concerning annulment. The ruling expands the scope of what can be considered evidence of psychological incapacity, including seemingly minor acts of irresponsibility, such as a spouse's persistent failure to do household chores or care for their children. It stresses that a persistent pattern of neglect, irresponsibility, and infidelity can be considered a manifestation of a deep-seated personality flaw that makes a person incapable of fulfilling the legal and moral bond of marriage.

For those who are in a similar situation, this decision offers a clear way forward, confirming that a marriage without a foundation of mutual love, respect, and responsibility is already void from the beginning. To understand how this ruling might apply to your specific situation, it is best to consult with a legal professional. An experienced attorney in Manila or a trusted law firm in Iloilo City can provide the legal services you need. Finding a skilled litigation attorney or an attorney near you in Iloilo or Manila is an important step to ensuring your rights are protected and that you receive the guidance needed to pursue a favorable outcome.