THE Supreme Court ruled that testimonies from family members and close friends can be admitted as evidence to prove psychological incapacity in nullity of marriage cases.

In a decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the Supreme Court Second Division upheld the annulment of the marriage between Jeffery Green and Rowena Manlutac Green, ruling that Rowena was psychologically unfit for marriage from the beginning of their union.

Jeffery and Rowena were in a relationship for four years before marrying, but within another four years, Jeffery filed a petition to nullify their marriage, citing psychological incapacity on both sides.

He submitted a psychiatric evaluation that drew from standard psychological tests and interviews with himself, Rowena, a mutual friend, and Rowena's own mother.

The evaluation painted a troubling picture. Rowena had allegedly incurred debts totaling P4 million, lied about the paternity of their child, and was repeatedly unfaithful.

Based on her history and behavior, she was diagnosed with borderline personality disorder and antisocial personality disorder — both considered incurable and deeply rooted in unresolved childhood trust issues.

Supporting evidence included records of her financial mismanagement, gambling, and dishonesty. The Court noted these behaviors made it impossible for Rowena to fulfill her duties as a spouse.

"She refused to live with Jeffery, they had no fixed family home, she fabricated the paternity of their child, and despite being financially dependent on him, she continued to lie and accumulate debt, leading to both civil and criminal cases," the Court said.

The Regional Trial Court first granted the petition, which was later affirmed by the Court of Appeals and then by the Supreme Court.

The Supreme Court reiterated that in evaluating psychological incapacity under Article 36 of the Family Code, the testimonies of individuals other than the petitioning spouse are not only admissible but may even be more reliable.

"This is a realistic reception of psychological assessments," the Court said, adding that relatives and friends of the allegedly incapacitated spouse are unlikely to be hostile or biased witnesses.

Unless proven fabricated, their accounts provide meaningful insight into the spouse's longstanding mental state.