In this April 2019 case of Mary Christine C. Go-Yu vs. Romeo A. Yu, G.R. No. 230443, 3 April 2019, the Supreme Court had the occasion to reiterate the age-old jurisprudential adage that “an unsatisfactory marriage is not a null and void marriage.”
Here, it was the wife who filed a petition for declaration of nullity of marriage and the dissolution of the absolute community of property, wherein she enumerated the following circumstances of her marriage which prompted her to seek relief from the Court, thus:
- Both she and her husband stayed at the latter’s home after the marriage where she had to contend with the constant meddling of her mother-in-law and the mother-in-law’s constant intrusion into their privacy;
- Her husband’s promises to move out which were never fulfilled;
- The adjustments that she had to make which entailed a lot of sacrifice on her part such as but not limited to the giving up of some of the luxuries she was used to when her husband’s financial resources dwindled;
- The limitation of her social life after their marriage and her becoming withdrawn;
- Her act of single-handedly taken on the responsibility of running their household and making all the decisions as her husband was too busy with his involvement with personal and social activities outside their house;
- The considerable decrease in the spouses’ sexual activity after their wedding;
- Her inability to conceive and her husband’s refusal to allow her to undergo in-vitro fertilization; and
- Their growing apart as husband and wife which led them to live separate lives even though they stay under the same roof, among others.
Because of the all these circumstances, the wife claimed that she was diagnosed with “Narcissistic Personality Disorder”. According to her petition, this disorder existed before their marriage. And the fact that she (the wife) is comfortable with her behavior, sees nothing wrong with it or that she needed to change makes treatment improbable.
The Supreme Court, however, disagreed.
After evaluating the evidence presented by the wife herself, the Supreme Court found that the wife actually understood her marital obligations and even took steps towards fulfilling them. Hence, it gave little credence to the psychiatrist’s findings, ruling that the latter failed to sufficiently substantiate its report and specify the factual basis thereof or even state where the information was obtained.
While the Supreme Court did acknowledge that the wife was unhappy with her marriage and commiserated with her situation, the Supreme Court nonetheless said that the remedy is not to have the marriage declared void, as this remedy is only limited to certain grounds and situations, thus –
“The Court understands and commiserates with petitioner's frustration over her marital woes. However, "[t]o be tired and to give up on one's situation and on one's [spouse] are not necessarily signs of psychological illness; neither can falling out of love be so labeled. When these happen, the remedy for some is to cut the marital knot to allow the parties to go their separate ways. This simple remedy, however, is not available to us under our laws. Ours is x x x a limited remedy that addresses only a very specific situation — a relationship where no marriage could have validly been concluded because the parties, or [where] one of them, by reason of a grave and incurable psychological illness existing when the marriage was celebrated, did not appreciate the obligations of marital life and, thus, could not have validly entered into a marriage. Outside of this situation, this Court is powerless to provide any permanent remedy."
Significantly, apart from noting that the wife understood and actually took steps towards fulfilling her marital obligations, the Supreme Court also took into account the fact that it was the party claiming psychological incapacity who was filing the petition. This served to further weaken the evidentiary weight of the wife’s testimonial and documentary evidence, as the Supreme Court merely considered them as self-serving.
In the end, the High Court was constrained to uphold the marriage and deny the petition, ruling that “unless the evidence presented clearly reveals a situation where the parties, or one of them, could not have validly entered into a marriage by reason of a grave and serious psychological illness existing at the time it was celebrated, the Court will be compelled to uphold the indissolubility of the marital tie.”
(Aaron Jarveen O. Ho is the Managing Partner of HG Law and specializes in Labor and Employment Law, as well as Litigation and Dispute Resolution Matters. For questions or concerns, Atty. Ho may be reached through his e-mail address at firstname.lastname@example.org)