The Supreme Court of the Philippines has made a definitive ruling, declaring a marriage null and void based on the wife's severe psychological incapacity, which manifested in controlling and abusive behavior.
A Marriage Marred by Control and Distrust
The case, which reached the High Court, stemmed from the petition of Willy Tee Ten to annul his marriage to Nellie Chan Tee Ten. The couple was married on January 22, 1995. Willy presented evidence that Nellie's psychological issues existed even before their wedding, rooted in a privileged upbringing that fostered laziness and a lack of diligence.
After marriage, Nellie allegedly failed to perform her marital duties and dominated the relationship. A key point of contention was her demand for constant updates on Willy's whereabouts, forcing him to provide what he termed "proof of purchase"—photos of his location—when he was with a group.
Court Findings of Severe Psychological Disorder
The legal battle revealed deeper issues. The court heard testimonies describing Nellie as arrogant and disrespectful towards Willy's mother. More seriously, she was accused of psychological abuse towards their children, including attacking Willy while he was holding one of their daughters.
In one alarming incident, Nellie secretly entered Willy's mother's house and took their children without informing anyone. A clinical psychologist testified that Nellie suffered from Narcissistic Personality Disorder with paranoid features, which was deemed grave and incurable. The expert recommended the annulment of the marriage.
Landmark Ruling and Legal Precedent
In its 14-page decision for the case Tee Ten vs. Tee Ten (G.R. No. 259322), penned by Associate Justice Henri Jean Paul Inting and promulgated on August 6, 2025, the Supreme Court Third Division affirmed the lower courts' rulings.
The High Court applied the standards set in the landmark Tan-Andal vs. Andal case. It found that Nellie's psychological incapacity was:
- Grave and incurable.
- Present prior to the marriage.
- The root cause of her inability to fulfill essential marital obligations.
The Court upheld the findings of the Regional Trial Court and the Court of Appeals, giving weight to the psychological report and witness testimonies. It dismissed Nellie's counter-allegations against Willy and denied her appeal.
This ruling reinforces the legal principle that for a marriage to be annulled under Article 36 of the Family Code due to psychological incapacity, the condition must be juridically antecedent, severe, and ultimately prevent a spouse from complying with the fundamental responsibilities of marriage.
