SC nullifies marriage on grounds of wife's 'controlling, demanding' ways

The Supreme Court has affirmed a decision that nullified a marriage because of a wife's "psychological incapacity" for being "controlling and demanding" towards her husband.

Based on a 14-page decision dated August 2025, an initial petition to nullify the 1995 marriage was filed by the husband in 2003 after he stated that his wife was "domineering, controlling, demanding, and had an excessive amount of entitlement."

He claimed that she always demanded to know of his whereabouts, had been accusing him of having incestuous relations with his mother, and that his wife was both physically and verbally abusive.

The court also noted a clinical diagnosis stating that the wife had "Narcissistic Personality Disorder with paranoid features" and that she had a grave and incurable psychological incapacity to perform her marital obligations.

In response, the wife stated that the husband had been physically, verbally, and sexually abusive of their children.

The wife also questioned the medical diagnosis made on her person, claiming it was based on biased statements of her husband and colleagues and that she had not been examined personally.

Mutual love and respect

In an earlier ruling in 2016, the Pasig Regional Trial Court (RTC) had nullified the marriage on grounds of the wife’s psychological incapacity.

The Court of Appeals (CA) reaffirmed the ruling in 2017 following a motion of reconsideration from the wife, which was denied.

In a petition for reconsideration, the wife claimed that the court had not considered that she was not examined by the doctor who diagnosed her and that her claims of her husband’s abuse were not acknowledged.

In the final decision, the Supreme Court ruled that the petition was without merit.

The court cited the case of Tan-Andal vs. Andal, which stated that psychological incapacity meant that it was grave enough to cause inability, existed prior to or during the marriage, and was incurable.

“The actions of [the wife] demonstrate an undeniable pattern of failure on her part to comply with her essential marital obligations to [the husband]. Thus, the CA correctly upheld the RTC Decision which declared the parties' marriage void on the ground of [the wife’s] psychological incapacity,” the decision read.

"The most basic of these obligations is, of course, the duty of the husband and wife 'to live together, observe mutual love, respect and fidelity, and render mutual help and support,'" added the SC in its ruling.

The decision also noted that it was the wife herself who refused the initial psychological assessment that led to her diagnosis, which made it acceptable to base the clinical assessment on collateral information.

“After a careful consideration, the Court finds that the totality of the evidence shows that [the wife] is psychologically incapacitated to comply with her essential marital obligations to [the husband],” it added.

The court officially denied the petition and ordered the case remanded to the Pasig RTC for the determination of the support pendente lite and the distribution of co-owned properties in accordance with the Family Code. —VAL, GMA Integrated News