In Clavecilla vs. Clavecilla, et al, the Supreme Court discussed that it does not see any reason why the principle of clean hands should prevent a psychologically incapacitated spouse from initiating a proceeding to annul a marriage. This is because there is no party at fault in case of annulment of marriage based on psychological incapacity. Culpability cannot be imputed on the part of the spouse said to be psychologically incapacitated since it is not deliberate or intentional on his or her part to possess such personality trait. By reason of psychological incapacity, it cannot be said that bad faith had motivated the afflicted spouse to enter into a marriage or to even seek for a declaration of its nullity. It must be emphasized that the unclean hands doctrine only avails in cases of inequity, which does not exist in a marriage sought to be annulled on the basis of psychological incapacity of a spouse to comprehend and discharge the concomitant marital obligations.

Most importantly, Article 36 of the Family Code does not prohibit the psychologically incapacitated spouse from initiating the action. Indeed, under the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages, the Court allows either of the spouses to file the petition, alleging specifically, the facts showing the incapacity of either or both of them.