In Green vs. Green, et al. (G.R. No. 255706, February 17, 2025), the Supreme Court ruled that statements from a spouse’s family and close associates may be used to support claims of psychological incapacity in nullity of marriage cases.

In a decision penned by Senior Associate Justice Marvic Leonen, the Court voided the marriage of a couple, citing a party’s psychological condition. The Petitioner therein submitted a psychiatric report based on interviews with himself, his spouse, a mutual friend, and the wife’s mother. The report pointed to chronic debt, infidelity, and dishonesty, including misrepresenting the paternity of their child.

The SC emphasized that evidence from people close to the incapacitated spouse is valuable, as it can offer more objective insight than testimony from the spouses alone. It also reaffirmed that under Article 36 of the Family Code, psychological incapacity existing at the time of the marriage can justify annulment.

The wife therein was diagnosed with Borderline Personality Disorder and Antisocial Personality Disorder, found to be incurable and incompatible with fulfilling marital duties.