PH Supreme Court says spouses' shared desire for annulment is not collusion

The Supreme Court of the Philippines has ruled that a husband and wife's shared desire to end their marriage does not, by itself, constitute collusion in a petition to declare a marriage void.

In a decision penned by Associate Justice Maria Filomena D. Singh, the Court's Third Division upheld a ruling declaring a marriage void due to the husband's psychological incapacity, rejecting claims that the spouses had conspired to obtain the annulment.

The case stemmed from a petition filed by the wife, who alleged that her husband had subjected her to physical, psychological, and economic abuse that began even before they married.

After the husband failed to file an answer, the Regional Trial Court ordered the Provincial Prosecutor to investigate possible collusion. The prosecutor later concluded that no collusion existed.

During the proceedings, the wife presented witnesses, including a clinical psychologist as well as the husband's father and cousin, who testified about his abusive behavior and personal vices. The husband neither presented evidence nor opposed the petition.

Despite these testimonies, the trial court dismissed the petition, finding that psychological incapacity had not been sufficiently established. It also questioned the credibility of the husband's relatives, noting that they appeared to support the wife's case and that the husband was willing to have the marriage annulled.

The Court of Appeals later reversed the ruling, concluding that the evidence was sufficient to establish psychological incapacity.

The Republic, through the Office of the Solicitor General, elevated the case to the Supreme Court, arguing that the spouses had colluded to have their marriage declared void.

The High Court disagreed, explaining that collusion requires a secret agreement to deceive the court by fabricating or concealing facts to obtain a favorable ruling. It cited the case of De Ocampo v. Florenciano, which defined collusion as spouses working together to create, fake, or hide marital offenses to secure the dissolution of their marriage.

The Court also reiterated that existing laws require the State, through public prosecutors, to participate in annulment and nullity proceedings to determine whether collusion exists. If collusion is established, the petition must be dismissed.

In this case, however, the Supreme Court said the circumstances cited by the trial court were insufficient to prove that the spouses conspired to fabricate grounds for nullifying their marriage.

The Court stressed that a spouse's consent to or failure to oppose an annulment petition does not automatically amount to collusion. Likewise, the husband's failure to file an answer or present evidence did not, by itself, establish a scheme to mislead the court.

Finding the evidence sufficient, the Supreme Court affirmed the Court of Appeals' ruling that the husband was psychologically incapacitated, citing witness testimonies and the psychological evaluation presented during trial.

The Court also underscored that while marriage is protected by law, courts should not ignore situations where the relationship has become irreparably harmful.

"Marriage, in its truest form, must be a sanctuary: a space of mutual respect, care, and emotional safety. It must never become a chain that binds a person to a relationship that is not only fundamentally flawed, but damaging. While the ideal remains that individuals choose wisely in love and commitment, the reality is that human beings make mistakes. When a marriage has become irreparably broken, the spouses so deeply incompatible as to render its continued existence unjust, the Court should not stand in the way."

-Paraluman News