Republic v. Angelique Pearl Claur

Summary

The Supreme Court affirmed the nullity of marriage between Angelique Pearl and Mark Claur based on psychological incapacity of both parties. Applying the landmark Tan-Andal doctrine, the Court clarified that psychological incapacity is a legal concept requiring clear and convincing evidence of three elements: juridical antecedence, gravity, and incurability. The evidence showed both parties suffered from personality disorders (borderline and narcissistic respectively) that existed before marriage, were grave enough to prevent performance of essential marital obligations, and created incompatible personality structures making the marriage's breakdown inevitable. The decision reinforces that psychological incapacity can be established through ordinary witness testimony and expert opinion based on collateral information, without requiring direct examination of the allegedly incapacitated spouse. The case demonstrates the Court's balanced approach to protecting marriage as a social institution while recognizing that void marriages deserve no legal protection.