Antonio and Maribel Quiogue were married in 1980. For nearly two decades, they tried to make their marriage work. Eventually, however, the relationship collapsed. By 1998, the spouses were already living separately. A few years later, Antonio filed a petition to declare their marriage void on the ground of psychological incapacity.

What made the case unusual was that Antonio did not portray himself as an innocent husband. He openly admitted that throughout the marriage he had engaged in multiple extra-marital affairs. At various points, Maribel discovered his relationships with other women. Their marriage fell into a cycle of infidelity, confrontation, temporary reconciliation, and yet another affair.

Maribel confronted Antonio’s mistresses, sent angry messages, publicly embarrassed him, and repeatedly expressed her outrage over his womanizing. Their children became aware of the conflicts. Eventually, the marriage deteriorated beyond repair. Could Antonio’s repeated infidelity amount to psychological incapacity?

Yes. The Supreme Court began by emphasizing that not every act of infidelity constitutes psychological incapacity. A single affair, standing alone, does not automatically make a marriage void. Nor does every adulterous spouse qualify as psychologically incapacitated.

However, the Court found that Antonio’s womanizing was not an isolated lapse in judgment. Rather, it was part of a deeply rooted and enduring pattern of behavior that predated the marriage itself. Before marrying Maribel, Antonio had already engaged in overlapping romantic relationships. Even after marriage, he repeatedly pursued other women despite knowing the pain his conduct caused his wife and children.

The psychiatric evidence traced this pattern to Antonio’s upbringing. He grew up watching a father who openly maintained relationships with multiple women and fathered children outside marriage. Although Antonio resented his father’s conduct, he eventually mirrored the same behavior. According to the psychiatrist, Antonio developed narcissistic and histrionic personality traits that fueled his constant need for attention, validation, and ego gratification through relationships with other women.

More importantly, the Court observed that Antonio never truly understood fidelity as an essential obligation of marriage. At one point, he essentially described himself as a good husband despite his repeated affairs. He viewed his infidelity as something Maribel should have tolerated or handled differently. Rather than taking responsibility, he blamed his wife for not helping him overcome his womanizing.

For the Supreme Court, this demonstrated something more serious than ordinary marital misconduct. It showed an enduring inability to comply with one of the most fundamental obligations of marriage: fidelity.

Accordingly, the Court ruled that Antonio’s chronic infidelity constituted psychological incapacity. His condition existed before the marriage, persisted throughout the marriage, and rendered him genuinely incapable of faithfully performing the obligations expected of a husband. For that reason, the marriage was declared void.

Quioge v. Quioge. G.R. No. 203992, August 22, 2022.