'Inability to love' due to personality disorder a ground to nullify marriage —SC

A spouse’s inability to love due to a genuine personality disorder may be considered evidence of psychological incapacity and grounds to declare a marriage void, the Supreme Court (SC) ruled. 

“Psychological incapacity may manifest long after the solemnization of a marriage,” the SC Second Division said in a 16-page decision. 

“A spouse who previously seemed capable of performing his marital obligations may prove to be incapable of doing so, and the marriage must be voided so long as the incapacity is shown to be due to a genuine psychic cause,” it added.

In its ruling, the SC reinstated an earlier ruling of a regional trial court (RTC) that declared a marriage void from the beginning due to the husband’s psychological incapacity to fulfill his marital duties. 

The SC said the couple had only been physically together for five years of their marriage due to the husband’s work abroad. It said this was marked by frequent arguments and periods of separation. 

According to the Court, the husband filed a petition to nullify the marriage in 2016, providing a psychologist’s diagnosis of his passive-aggressive personality disorder. 

Though the RTC granted the petition, it later reversed it amid concerns about due process. The Court of Appeals also denied the husband’s appeal.

However, the SC said that the husband sufficiently proved his psychological incapacity.

The High Court noted that due to the husband’s childhood, he maintained emotional distance in relationships and learned how to bottle up his true emotions and feelings to keep the peace.

It said that though the husband can provide for the family’s material needs, such as financial support, he lacks in providing emotional needs.

“Loving one’s spouse is an important, if not the most important, essential marital obligation. Petitioner already asserted that he no longer loved private respondent. He also proved that his inability to love private respondent back is rooted in a durable part of his personality, caused by a potentially emotionally immature parent,” the SC said.

“For these reasons, petitioner must not be forced to stay in a loveless marrriage, and his marriage to private respondent must be voided,” it added. 

The decision, penned by Senior Associate Justice Marvic Leonen, was promulgated in November 2024 and made public in June 2025. —VAL, GMA Integrated News