01/07/2026
The Supreme Court Speaks: Psychological incapacity is a legal concept, not a medical illness, and does not require a clinical diagnosis.
In Juanito B. Soto v. Cassandra Reyes-Soto and the Republic of the Philippines, G.R. No. 249759, April 22, 2026, the Court affirms the grounds of nullity of a marriage based on the psychological incapacity of spouses under Article 36 of the Family Code.
Juanito Soto and Cassandra Reyes-Soto met when they were college students at the University of the Philippines, and eventually became a couple in 1981. When Cassandra learned she was pregnant in 1983, the couple got married in September 1983. Even before the marriage, Cassandra harbored reservations about their relationship due to Juanito’s distant nature, and after the birth of their daughter, Carmela, they still seldom went out as a family. The couple stopped engaging in intimate activities in 1986. In 1988, Juanito decided to seek employment in the US, with the agreement that Cassandra and their daughter would join them once they were stable; however, Cassandra eventually decided against it. During his time in the US, Juanito didn’t maintain stable, consistent communication with either Cassandra or their daughter. In 1994, the couple was granted a divorce in the US. After Juanito’s permanent return to the Philippines, Cassandra refused to reconcile and eventually filed a petition for the declaration of nullity of their marriage under Article 36 of the Family Code. The RTC granted the petition, finding both parties psychologically incapacitated. After appealing, CA initially reversed RTC’s decision, but later issued an Amended Decision noting that, upon reexamination, the findings adequately established the spouses’ psychological incapacity.
The Court denied the petition, ruling that there was clear evidence that both parties suffered from personality structures that rendered them incapable of fulfilling their essential marital duties. The respondent, Cassandra, diagnosed with Passive-Aggressive Personality Disorder, causes her to react to marital stress passively and unexpressed anger, leading to total emotional withdrawal. On the other hand, the petitioner, Juanito, was diagnosed with Inadequate Personality Disorder with an Oedipal complex, resulting in his inability to separate filial attachment from marital intimacy, causing him to be emotionally immature, unable to provide security and affection to his spouse and daughter. The Court finds these conditions to be adequate in meeting the required criteria, with juridical antecedence rooted in the parties’ formative years, incurability seen in the endurance of the situation despite decades of separation, and the gravity of the situation, which prevented the parties from understanding or assuming the essential obligations of a marriage.
The Court, in its final note, affirms that, while no government can legislate love into a marriage, it can create a humane and accepting legal space that allows people who entered into a marriage without the concomitant psychological capacity to live up to their marital obligations to come to terms with this truth and, with hope and dignity, begin again.
Read the full Supreme Court Decision: https://sc.judiciary.gov.ph/249759-juanito-b-soto-vs-cassandra-reyes-soto-and-the-republic-of-the-philippines/
