A spouse, who married an individual with dysfunctionality and could not understand and comply with essential marital obligations due to psychological causes, “is not condemned to a life sentence of misery.”

After all, marriage – despite being an inviolable social institution – “was never intended to be a prison,” said the Court of Appeals (CA) which reiterated the Supreme Court (SC) decision issued in 2023.

With its ruling, the CA granted the petition of the wife and reversed the order of the regional trial court (RTC) which denied her petition for nullity of marriage filed in 2014.

The names of the spouses were redacted by the Manila Bulletin to protect the privacy of the parties and their two children.

The CA decision in the case, docketed as CA-G.R. CV No. 122585, was promulgated on Oct. 15, 2025 and written by Associate Justice Ronaldo Roberto B. Martin.

The spouses were married in 2003. After 11 years of marriage and with two children, the wife filed before the trial court a petition for nullity of marriage on the ground of her husband’s psychological incapacity under Article 36 of the Family Code of the Philippines.

She told the RTC that their marriage was doomed from the start due to lack of love, respect, understanding, honesty and support from her husband who was “carefree, promiscuous, and irresponsible womanizer.”

She also said that she suffered “extreme anguish” during their marriage due to her husband’s repeated verbal and physical abuse.

After their wedding, the wife said they lived with her husband’s family.

However, she said, she was constantly berated by her husband and they were solely dependent on his parents for their basic needs.

She also said she was a battered wife, physically and emotionally, since her husband was “insensitive to even her most serious emotional needs, making her feel unimportant and rejected without respect.”

When she could no longer take her husband’s physical and emotional abuse, she said she left him and started living with her parents.

In 2005, she said she gave her husband a chance to reunite their family. But, she said, her husband's “immaturity and insensitivity” persisted. She then filed a petition for nullity of marriage.

The wife’s petition was dismissed on Jan. 28, 2016 when she and her husband failed to appear when summoned by the prosecutor to a conference.

On the wife’s motion which cited the death of her counsel, the RTC reinstated her petition on March 9, 2016.

In a decision handed down on May 2, 2023, the RTC dismissed the wife’s petition for insufficiency of evidence. The wife appealed before the CA.

In resolving the issue in favor of the wife, the CA said that she “was able to establish the psychological incapacity of appellee (husband), as well as its juridical antecedence, incurability, and gravity, as required by Article 36 of the Family Code, as amended, and recent jurisprudential pronouncements.”

It said that while getting married at a young age, the wife was fully cognizant and capable of performing the essential marital obligations.

However, it said the gravity of the husband’s psychologically incapacity was proven by his “failure to comply with his essential marital obligations, such as observing mutual love, respect, fidelity, and rendering mutual help and support to his wife, due to his constant infidelity and persistent failure to sustain a job and contribute to the family’s expenses.”

As earlier found through testimonies, the CA said that the husband was constantly and openly engaged in extramarital affairs to the extent that the family was aware of his wrongdoings.

It added that it was also proven that throughout their marriage, the husband was solely dependent on his mother and sister to support himself, his wife, and his two children.

The CA ruled: “Clearly, appellee’s (husband) evident disregard and lack of concern for his responsibilities as a husband and father, i.e., failure to provide financial support and engagement in extramarital relations, are indicative of the fact that he is not cognizant of his essential marital obligations under the Family Code. Such psychological incapacity is enough to declare the nullity of the parties’ marriage even if such incapacity became manifest only after its solemnization.”