Understanding Psychological Incapacity in Marital Nullity Jurisprudence: Qualitative Analysis of Selected Supreme Court Case Verdicts

Marriage, as a cornerstone of society, is afforded protection by the 1987 Philippine Constitution (Article XV). Yet, marital conflicts often lead to severe consequences for spouses and children. The Family Code of 1987, amended by E.O. 227, introduced psychological incapacity as grounds for declaring marriages void ab initio. This study analyzes 42 marital nullity cases (17 affirmed, 25 denied) from 2000 to 2022, sourced from Lawphil, to uncover distinctions in verdicts by the Regional Trial Courts (RTC) and Supreme Court (SC). Using thematic narrative analysis, four key stages emerged: courtship, marital life, conflict, and case procedure. Affirmed and denied cases differed in evidence presentation, particularly regarding the severity, juridical antecedence, and incurability of psychological incapacity. RTC decisions primarily relied on the presented evidence, while the SC adopted a holistic approach, considering the illness's gravity, antecedence, and incurability. Direct psychological assessments were pivotal in affirmed cases, while indirect assessments were insufficient for denied cases. Some rulings equated psychological incapacity with personality disorders or mental illness, causing inconsistencies, especially in determining gravity, antecedence, and incurability. The study underscores the need for recognized psychologists or clinical experts to address marriage-related cases involving psychological incapacity, ensuring a more precise application of the Family Code.