SC rules decades-long absence can indicate psychological incapacity

The Supreme Court ruled that a decades-long absence from the marital home can be considered evidence of psychological incapacity in fulfilling marital obligations.

In its decision on April 17, 2024, the court granted Leonora Dela Cruz-Lanuza's petition to nullify her marriage to Alfredo Lanuza, Jr., citing his long absence and failure to provide financial support.

Leonora and Alfredo married in 1984 but separated after ten years due to Alfredo's changed behavior, infidelity, and refusal to provide financial support.

The court emphasized that spouses are required to live together, observe mutual love, respect, and fidelity under Article 68 of the Family Code.

Justice Marvic Leonen noted that Alfredo's psychological incapacity originated from his childhood experiences, including a lack of appropriate parental supervision and encouragement to be assertive.

His disorder developed during formative years and persisted into marriage, making him unable to fulfill his duties as a husband and father.