Rosanna and Mario married in 1995. Their marriage quickly deteriorated. According to Rosanna, Mario would disappear for days without explanation. He repeatedly used illegal drugs, drained company funds, abandoned family responsibilities, displayed erratic and paranoid behavior, and repeatedly failed to provide support to his wife and daughter. On several occasions, he had to be confined for detoxification and rehabilitation. Yet despite repeated opportunities to change, the problems persisted.

Eventually, Rosanna filed a petition to declare their marriage void on the ground of psychological incapacity. To support her case, she presented a psychiatrist who diagnosed Mario with narcissistic antisocial personality disorder and substance abuse disorder with psychotic features. According to the psychiatrist, these conditions rendered Mario incapable of complying with the essential obligations of marriage.

Was the marriage void?

Yes. According to the Court, psychological incapacity is not necessarily a mental illness. It is not even necessarily a personality disorder. Courts should not require parties to label a spouse with a psychiatric diagnosis simply to obtain a declaration of nullity.

The Court emphasized that psychological incapacity concerns a person’s enduring personality structure and whether that structure makes it truly impossible for the spouse to understand and comply with the essential obligations of marriage. What matters is not the medical label. What matters is the actual behavior and its effect on the marital relationship.

Ordinary witnesses who personally observed the spouse’s behavior may provide sufficient evidence. Expert testimony remains useful, but it is no longer indispensable.

Applying these principles, the Court found that Mario’s persistent drug abuse, irresponsibility, emotional instability, neglect of his wife and child, repeated rehabilitation failures, and inability to discharge basic marital and parental duties demonstrated psychological incapacity. The evidence showed not mere difficulty or unwillingness to perform marital obligations, but a genuine inability to do so.

Tan-Andal v. Andal. G.R. No. 196359, May 11, 2021.