Halili vs.

Halili (June 9, 2009)

Facts:

A married B. A thought it was a joke. After the ceremonies, A and B never lived together as husband and
wife, but maintained the relationship. They started fighting constantly a year later, so A decided to stop
seeing B and started dating other women. Immediately thereafter, A received prank calls telling him to
stop dating other women as he was already a married man. It was only upon further inquiry that A
found out that the marriage was not fake.

The expert psychologist testified that A was suffering from a mixed personality disorder: self-defeating
personality disorder to dependent personality disorder. Such was brought about by A’s dysfunctional
family. A didn’t understand the implications of being married and there was no consummation of the
marriage at all, let alone a shared residence as husband and wife.

Issue:

Is A psychologically incapable for marriage? Is the marriage void?

Ruling:

A is psychologically incapable and the marriage is void. Courts should interpret the provision on
psychological incapacity on a case-to-case basis guided by (a) experience, (b) the findings of experts and
researchers in psychological disciplines, and (c) by decisions of church tribunals.

Dependent personality disorder definition: characterized by a pattern of dependent and submissive

behavior. Those suffering from this usually lack self-esteem and frequently belittle their capabilities;
they fear criticism and are easily hurt by other comments. At times they actually bring about dominance
by others through a quest for overprotection.

Manifestations of dependent personality disorder in A: He was very much attached to his parents and
depended on them for decisions. His mother even had to be the one to tell him to seek legal help when
he felt confused as to what action to take upon learning that his marriage to B was for realzzz.

Most importantly, his personality disorder was GRAVE AND INCURABLE and ALREADY EXISTENT AT THE
TIME OF MARRIAGE. This rendered him unable to perform the essential obligations of marriage.