Are personality disorders enough bases to nullify marriage?
By Tetch Torres
Posted date: April 01, 2010
MANILA, Philippines—Being a “mama’s boy,” immature, or self indulgent, are not grave enough causes to allow the annulment of marriage, the Supreme Court said.
Jordan and Jeanice Paz met on November 1996, became a couple on May 10, 1997 and got married two months later. She gave birth to a son in 1998 but left Jordan a year later after a big fight.
She filed a petition for declaration of nullity of marriage against Jordan in 1999 accusing her husband of being psychologically incapable of assuming the essential obligations of marriage.
Jeanice said her husband had a tendency to lie about his whereabouts, had the habit of hanging a great deal of time with his friends. Since Jordan worked in their family business, he opted to stay home and tinker with his playstation. She said Jordan even asked her to lie to his brother about his whereabouts. She added that after giving birth to their son, her husband demanded from his mother a steady supply of milk and diapers. She added that he subjected her to verbal lashing and even threatened to hit her with a golf club.
Psychologist Cristina Gates testified that Jordan has a “borderline personality disorder” due to his impulsive behavior, delinquency and instability and with no indication of reformation, his disorder was grave and incorrigible.
Jordan argued that even his wife was also immature, childish and was emotionally unable to cope with the struggles of maintaining a married life. He also questioned Gates’ findings saying she did not interview him.
The Pasig City Regional Trial Court Branch 69 in 2003 nullified the marriage of Jordan and Jeanice based on the findings of Gates which was also affirmed by the Court of Appeals in 2004.
But the high court reversed the findings of both courts as it pointed out that for a marriage to be annulled, the psychological disorder must be “confined to the most serious cases of personality disorders clearly demonstrative of an utter insensitivity or inability to give meaning and significance to the marriage.”
“Moreover, contrary to the ruling of the trial court, Jordan’s alleged psychological incapacity was not shown to be so grave and so permanent as to deprive him of the awareness of the duties and responsibilities of the matrimonial bond. At best, Jeanice’s allegations showed that Jordan was irresponsible, insensitive, or emotionally immature. The incidents cited by Jeanice do not show that Jordan suffered from grave psychological maladies that paralyzed Jordan from complying with the essential obligations of marriage.”
“What the law requires to render a marriage void on the ground of psychological incapacity is downright incapacity, not refusal or neglect or difficulty, much less ill will,” the high court said.
The high court added that all people may have certain quirks that can be attributed to isolated characteristics associated with certain personality disorders but that is not enough to invalidate a marriage.
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