Spouses' mutual desire to end marriage per se not proof of collusion: SC
The Supreme Court has ruled that the mutual desire of spouses to end their marriage does not alone prove collusion in annulment cases.
In a decision written by Associate Justice Maria Filomena D. Singh voiding a marriage, the SC's Third Division said it found no evidence that the spouses involved in the petition did not secretly agree "to fake or misrepresent facts in order to nullify their marriage."
According to a press release shared by the SC spokesperson on July 2, the petition was filed by the wife at the Regional Trial Court. She alleged her husband could not fulfill his marital duties due to consistent "physical, psychological, and economic abuse" since before they got married.
Because the husband did not file a reply to the petition, the RTC ordered the provincial prosecutor to find evidence of collusion between the spouses. After the investigation, the associate provincial prosecutor said there was no collusion.
At the trial, the wife presented several witnesses, which included a clinical psychologist, as well as the husband's father and cousin. The family members attested to the husband's vices and abusive behavior.
The husband did not present any witnesses, neither did he object to the petition.
Nevertheless, the RTC dismissed the annulment petition, not seeing enough evidence proving the husband's psychological incapacity, and doubting honesty in the husband's relatives' testimonies.
While the Court of Appeals reversed the RTC's decision, an appeal was brought in front of the SC, alleging the couple colluded in the wife's petition.
Disagreeing with the appeal, the SC wrote the RTC's suspicions did not prove collusion.
According to the SC, a spouse's agreement or lack of objection does not equate to a secret plot to mislead the court. To establish collusion, the court needed proof that the spouses faked evidence or hid facts.
In its decision, the SC further acknowledged that some marriages may reach a point of no return, at which time it should be allowed to become nullified: "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."
