A husband’s “infidelity, failure to give support to his wife and children, and unjustified absence from his family are all indicative that he is not cognizant of the duties and responsibilities of a husband and father.”
Thus, the Supreme Court (SC) ruled that the marriage in 1984 between the husband, Alfredo, and wife, Leonora, should be voided on the ground of psychological incapacity.
The ruling was contained in a decision that was promulgated last April 17 and posted on the SC’s website – sc.judiciary.gov.ph – on Thursday, Aug. 29 under GR No 242363. It was written by Senior Associate Justice Marvic M.V.F. Leonen.
The SC decision granted the petition of Leonora as it reversed the rulings issued by both the Court of Appeals (CA) and the regional trial court (RTC).
Case records show that Alfredo and Leonora separated in 1994 after 10 years of marriage.
When Leonora found that Alfredo married another woman, she filed a case for bigamy against her husband. But the case was archived because Alfredo could not be located.
Alfredo was a police officer. He was dismissed from the service because of the bigamy case.
The records also show that Alfredo married another woman in 2000.
Leonora said that Alfredo abandoned his family and did not provide any financial support.
She underwent a psychological evaluation and the psychologist concluded that Alfredo was psychologically incapacitated to comply with his marital obligations.
On Dec. 27, 2017, the RTC dismissed the nullity of marriage case filed by Leonora. The trial court ruled that the pieces of evidence presented to prove Alfredo’s subsequent marriages were insufficient.
The RTC said that assuming Alfredo had two subsequent marriages, it also establishes infidelity which is sufficient to prove psychological incapacity.
It also said that there should be other circumstances and situations showing Alfredo's actions and inactions to show his aberrant attitudes and behavioral patterns demonstrating his total personality and his psychological illness.
When Leonora’s motion for reconsideration was denied by the RTC, she appealed before the CA which, in effect, affirmed the trial court’s ruling due to a technicality. She then elevated her case to the SC.
The SC said:
“Based on the facts, respondent (Alfredo) left his family in 1994 and appears to have contracted marriage several times, with different women. He never gave financial support to his children and only visited them once, for less than an hour. These indicate that respondent did not understand his obligations as a husband and father.
“To restate, the gravity of respondent's personality disorder is shown by his lack of recognition that he has responsibilities to his wife and children. His personality disorder appears to have been fostered by how he was raised by his family as ‘he was deprived of appropriate parental supervision and guidance’ and ‘his parents' lenient and tolerable attitude encouraged him to become extremely assertive.’ This shows that there is juridical antecedence. His psychological incapacity developed during his formative years and existed prior to his marriage to petitioner (Leonora).
“The incurability of respondent's personality disorder was also explained by the psychologist when he stated in his judicial affidavit that those who are diagnosed with narcissistic personality disorder ‘strongly deny that they are mentally ill, reject the idea of seeking professional help and therefore refuse any form of psychiatric treatment.’
“Accordingly, the Petition is granted. The May 31, 2018 and Oct. 2, 2018 Resolutions of the Court of Appeals in CA-G.R. SP No. 155807 are reversed and set aside. The marriage of petitioner Leonora… and private respondent Alfredo… is void on the ground of psychological incapacity. So ordered.”
