Ma. Armida Perez-Ferraris v. Brix Ferraris

Summary

This Supreme Court case involved a petition for declaration of marriage nullity based on psychological incapacity under Article 36 of the Family Code. Petitioner Ma. Armida Perez-Ferraris sought to nullify her marriage with Brix Ferraris, alleging he suffered from mixed personality disorder, epilepsy, sexual infidelity, and abandonment. All three court levels denied the petition, finding insufficient evidence of true psychological incapacity. The Supreme Court emphasized that psychological incapacity must be a serious, permanent psychological illness existing before marriage that deprives one of awareness of marital duties. The Court distinguished between genuine psychological incapacity and mere refusal or unwillingness to perform marital obligations, reinforcing that unsatisfactory marriages cannot be declared void ab initio without clear proof of debilitating psychological condition. The decision upholds the constitutional sanctity and indissolubility of marriage.