27/06/2025
THE COURT CANNOT FORCE A SPOUSE TO STAY IN A LOVELESS MARRIAGE—SUPREME COURT
| The Supreme Court (SC) has ruled that a spouse’s “inability to love or emotionally connect with their partner,“ if rooted in a genuine personality disorder, could be deemed as evidence to prove psychological incapacity in marital obligations.
In a 16-page decision penned by Senior Associate Justice Marvic Leonen, the SC's Second Division granted the petition of Ronald Boado to annul his marriage to his wife, Florence Galvez-Boado, on the ground of his psychological incapacity.
Their love story started when they met in 1999. Roughly three years later, or in 2002, they decided to settle down and marry each other. Florence and Ronald decided not to live together immediately, as Ronald worked in Saudi Arabia.
During Ronald's brief vacation in 2004, they held a church wedding, after which the husband returned abroad. A year later, he came back to the Philippines, which served as their opportunity to live together. Ronald and Florence were blessed with two children: a son in 2007 and a daughter in 2012. As the years passed by, their relationship began to turn sour due to frequent misunderstandings and periods of separation.
In 2016, Ronald filed a petition for nullification of marriage on the ground of his psychological incapacity. He attached a psychologist's diagnosis, which showed that he had passive-aggressive personality disorder—an illness marked by emotional detachment and difficulty maintaining close relationships.
Initially the Regional Trial Court granted the petition, saying the petitioner had sufficiently proven psychological incapacity in a legal sense, but the said ruling was later reversed by the Court of Appeals. This prompted Ronald to elevate the case before the Supreme Court.
In reinstating the RTC's ruling and deciding in favor of Ronald, the high court said his psychological incapacity had been sufficiently proven. It cited Article 36 of the Family Code, which states that a marriage may be declared void if one or both spouses are psychologically incapable of fulfilling essential marital obligations—even if such incapacity manifested only after the wedding.
The SC found that Ronald's incapacity was deeply rooted in his personal character and had existed before the marriage. It emphasized that psychological incapacity may not be immediately visible and may surface only later in the relationship.
It added that Ronald's inability to emotionally connect stemmed from an upbringing marked by strictness and emotional immaturity from his parents. While he could provide for his family financially, he struggled to meet his wife’s emotional needs, including basic companionship.
“Loving one’s spouse is an important, if not the most important, essential marital obligation,” the Supreme Court said.
The SC ruled to grant Ronald's petition because of his inability as a husband to love his wife, which was caused by his psychological condition, adding that the court cannot force him to stay in a loveless marriage.
