Marital Obligations and Psychological Incapacity of Couples in Metro Manila

Marital Obligations and Psychological Incapacity of Couples in Metro Manila

Dr. Lourdes P. Jusay

Eulogio’’Amang’’ Rodriguez Institute of Science and Technology – Manila Campus, Manila, Philippines

DOI: https://doi.org/10.51244/IJRSI.2024.11120045

Received: 23 December 2024; Revised: 28 December 2024; Accepted: 30 December 2024; Published: 14 January 2025

ABSTRACT

Marriage is a universal act that binds people from different cultural backgrounds and serves as the foundation of every culture. The couple, while they are married, live together as husband and wife with their children. This study aimed to assess the marital obligations and psychological incapacity of the couples in Metro Manila. The study used the descriptive method of research. The results showed that the couple are expected to observe their essential marital obligations in building their family and conjugal life in the community. The psychological incapacity, on the other hand, was assessed with differently by the respondents based on their professional backgrounds. However, they were unanimous in their contention that the psychological incapacity must be severed, embedded in the dynamics of the personality of the couples and it was not only physical but mental in nature, such that the couples were incognizant to discharge their essential marital obligations. The marital obligations provide a strong fortress for a stable and satisfying relational life between couples.  They must perform these marital obligations to guarantee the continuance of marriage which is protected by the fundamental law of the land in the Philippines. The respondents have similar perspectives on marital obligations especially those from the same cultural orientations. The psychological incapacity, when demonstrably permanent, severe, and incurable, can have a devastating effect on an individual’s ability to enter into a fulfilling and healthy marriage.

Keywords: Marriage, marital obligations, Living Together, Mutual Support, Psychological Incapacity

INTRODUCTION

Marriage is defined as a permanent union between a man and a woman with the intention to establish their own family and conjugal life (1987 Constitution of the Philippines). It is in this union that the couple are obligated to live in their family home. The marriage mandates them to perform their essential marital obligations to each other which they avowed to follow. These include to love one another, live together, support each other and to observe loyalty (Family code of the Philippines).

As a married individual, the husband takes the lead role to support the family. The wife may take a different role, that is, a housekeeper at home. As a consequence, the toll of the financial challenges rested solely on the shoulder of the husband. He needed to be an economic man for his family to support the basic and wants of his family members.

The study was anchored on the family systems theory of Bowen (2017) which postulates that a system is more than the sum of its parts because essential properties arise from the interactions and relationships among the parts. Every member of the family affects others psychologically. All members must be cautious to maintain homeostasis in the family to insure its continuance as the basic unit in the community. The ecological theory of Bronfenbrenner was also significant in this study as it views the person who develops in a complex system of relationships affected by multiple levels of the milieu of people. The theorist viewed the person’s environment is a nestled arrangement of structures. He saw the structures as to how much of an impact these structures may have on the person.

The study aimed to assess the marital obligations, psychological incapacity, and employee performance of the respondents as a basis for an intervention measure. Specifically, the study sought to answer the following questions: 1 How do lawyers, psychologists, priests/laymen and couples assess marital obligations in terms of: (1.1) loving each other; (1.2) financial support; (1.3) living together; and (1.4) Fidelity? 2.Is there a significant difference in the assessments of the four groups of respondents on the abovementioned variables? 3. How do respondents assess the psychological incapacity as to: (3.1) Severity; (3.2) incurability; and (3.3) permanency? 4. Is there a significant relationship between marital obligations and psychological incapacity?

BACKGROUND OF THE STUDY

In all countries of the world, people get married.  It is inevitable not to get married.  As a result, people shall perform their essential marital obligations to their spouse as they avowed to perform them during the marriage.  However, during the subsistence of marriage, some people are unmindful to fulfill their obligations. This nonperformance of their obligations will make them psychologically incapacitated. The psychological incapacity, which becomes, severe, incurable and permanent, may adversely impact the marriage of the couple in the marriage.  This leads to the destruction of the marriage which the society gives high premium as it impacts the family as a whole.

Inevitably, the parties are obligated to observe their responsibilities to their family.  However, if a party or the couple regrettably disregards the marital obligations, this may cause irreversible consequence in the family. It does not only affect the couple but the children as well.  In extreme cases when the parties are not capacitated to live together, they may resort to the filing of annulment of their marriage. Psychological incapacity is a legal ground to make the bond of marriage severed. This is the only way the party can get out of the marriage relationship because divorce is not accepted yet in the Philippines

LITERATURE REVIEW

According to Lanozol et al. (2021), the couples who get married establish their family, which is the most basic unit of society, and the foundation of it is the parents. Everyone wants a home and a healthy family in mind and body relationship. A family is complete with parents and children.

Undeniably, the Department of Health (DOH, 2020) contended that safe and supportive families are crucial in helping young people develop their full potential and attain the best health in adulthood. There is increasing evidence that parenting behaviors predict positive outcomes.

Under the law, marital obligations include loving each other, showing support, living together, and becoming loyal. These will significantly help the preservation of family relations. (Molina vs Molina case as cited by Sanchez, 2016).

Marriage is crucial for Filipinos who are family-oriented people. This makes them vulnerable to everything that is happening inside their homes. Filipino families are not exempted from increased separation rates in married couples. One out of five marriages in the Philippines are in splitsville based on the data gathered from the Philippine Statistics Authority (2014).

An opinion by Reyes III (2020) asserts that within the legal framework, there exist private spheres that even the judiciary cannot penetrate. Specifically, courts have no authority to dictate how married couples live. A couple’s lifestyle is their own to create and define, free from legal imposition.

According to the article by Gorecho in Panay News (2021), the Supreme Court stated that psychological incapacity refers to a personal condition that prevents a spouse from fulfilling essential marital duties towards a specific partner. This incapacity might be present during the marriage but only becomes evident through subsequent behavior. Clear and convincing evidence is required to declare a marriage null and void.

Article 36 of the Family Code of the Philippines (as Amended by Executive Order 227) was signed into law in 1987 and from the DSM-V. Accordingly, a marital union that was contracted by an individual who was psychologically incapacitated to comply with his/her essential obligations to the marriage at the time of its celebration would be void, even if this incapacity became noticeably apparent only after the solemnization of marriage.

Notable cases include Chi Ming Tsoi v. Court of Appeals (G.R. No. 119190, January 16, 1997), where the Supreme the court held that one of the essential marital obligations under the Family Code is “to procreate children” based on the universal principle that the procreation of children through sexual cooperation is the basic end of marriage. That constant non-fulfillment of this obligation will finally destroy the integrity or wholeness of the marriage. In that case, the senseless and protracted refusal of one of the parties to fulfill the above marital obligation was considered equivalent to psychological incapacity. In Maria Teresa B. Tani-De la Fuente v. Rodolfo De la Fuente, Jr. (G.R. No. 188400, March 8, 2017), the Supreme Court granted the petition for declaration of nullity of marriage on the grounds of psychological incapacity, after considering expert testimony, held that the root cause of the respondent’s paranoid personality disorder was hereditary as his father suffered from a similar disorder. The expert witness, who was a clinical psychologist, stated that the respondent’s psychological disorder probably started during his late childhood years and developed in his early adolescent years. He explained that the respondent’s psychological incapacity to perform his marital obligations was likely caused by growing up with a pathogenic parental model. The juridical antecedence of the respondent’s psychological incapacity was also sufficiently proven during the trial.

In the Republic of the Philippines v. Liberato P. Mola Cruz (G.R. No. 236629, July 23, 2018), the Supreme Court appreciated both the expert witness’s testimony and the evidence’s totality. It granted the petition for declaration of nullity of marriage on the grounds of psychological incapacity. It held that the psychological report confirms that the clinical psychologist personally. It must be emphasized that there must be proof of a natal or supervening disabling factor in the person – an adverse an integral element in the personality structure that effectively incapacitates the person from really accepting and thereby complying with the obligations essential to marriage.

Nowadays, the family structure built by the couple through their marriage has changed dramatically. Separation from one or both parents due to increased divorce/annulment massive-scale labor migration in many areas of the world, leading to many children left at home in the absence of parental care, is affecting family well-being. (Sablaon and Madrigal, 2021).

METHODOLOGY

The study used the descriptive method of research. It describes the characteristics of a population or phenomenon being studied. It stated that the descriptive approach is relatively straightforward because variables are measured to explain behavior. At the most basic level, only one variable is measured. Then, it progressed from describing a single variable to describing the relationship among variables. It often involves determining how variables co-vary and relate to one another (Calmorin, 2019). This is a combination of descriptive and quantitative methods of research that attempt to assess the couples’ marital obligations and psychological incapacity.

The data were gathered through a questionnaire distributed to the respondents through Google Forms. As evaluative research, it assessed the respondents’ marriage obligations and psychological incapacity.

It was hypothesized that (1) there is no significant relationship among the assessments of the four groups of respondents on the marital obligations; and (2) there is no significant relationship between the marital obligations and psychological incapacity.

RESULTS

The results of the study are the following:

The study focused on the marital obligations and psychological incapacity of the couples in Metro Manila.  There were four (4) groups of respondents who answered the researcher’s made questionnaire with 0.89 computed Cronbach reliability with the total number of 214 respondents.  The respondents were 30 lawyers; 30 psychologists; 15 priests/laymen; and 139 couples who participated in the study.

Table 1 Population and Sample

Respondents	Population	Frequency	Percentage
Lawyers	50	30	0.14
Psychologist	50	30	0.14
Priests/Laymen	50	15	0.07
Couples	300	139	0.65
Total	450	214	1.00

Table 2 Respondents as to Profession

Profession	Lawyers		Psychologist		Priests/Laymen		Couples		Total
	f	%	f	%	f	%	f	%	f	%
Legal	30	100							30	0.14
Professional helpers			30	100					30	0.14
Religions					15	100			15	0.17
Couples							139	100	139	0.65
Total	30	100	30	100	15	100			214	100

Table 3 Respondents as to Age

Age	Lawyers		Psychologist		Priests/Laymen		Couples		Total
	f	%	f	%	f	%	f	%	f	%
51 years old and above					3	0.2	10	0.07	13	0.06
46-50 years old	5	0.16	3	0.1	10	0.67	30	0.22	48	0.22
41-45 years old	8	0.27	2	0.07	2	0.13	38	0.27	50	0.23
36-40 years old	12	0.4	3	0.27			20	0.14	35	0.16
31-35 years old	5	0.17	17	0.4			15	0.12	37	0.17
26-30 years old			5	0.16			20	0.14	25	0.12
21-25 years old							6	0.04	6	0.03
Total	30	100	30	100	15	100	139	100	214	100

Table 4 Respondents as to Sex

Sex	Lawyers		Psychologist		Priests/Laymen		Couples		Total
	f	%	f	%	f	%	f	%	f	%
Male	18	0.6	5	0.17	10	0.6	50	0.38	83	0.39
Female	12	0.4	25	0.83	5	0.4	89	.64	131	0.61
Total	30	100	30	1.00	15	100	139	100	214

Table 5 Respondents as to Civil Status

Civil Status	Lawyers		Psychologist		Priests/Laymen		Couples		Total
	f	%	f	%	f	%	f	%	f	%
Single	5	0.17	12	0.4	10	0.66	37	0.14	64	0.30
Married	10	0.33	15	0.5	5	0.34	94	0.60	124	0.57
Legally Separated	10	0.33					4	0.09	14	0.07
Widow/Widower	5	0.1	3	0.1			4	0.09	12	0.07
Total	30	100	30	100	15	100	139	100	214	100

Table 6 Respondents as to Educational Attainment

Educational Attainment	Lawyers		Psychologist		Priests/Laymen		Couples		Total
	f	%	f	%	f	%	f	%	f	%
Doctorate Degree	30	100	5	0.16	2	0.14	13	0.09	50	0.23
With Doctorate Units			10	0.34	5	0.33			15	0.07
Master’s Degree			10	0.34	5	0.33	30	0.22	45	0.21
With Master’s Degree			5	0.16	3	0.2	33	0.24	41	0.19
Bachelor’s Degree							60	0.43	60	0.28
Undergraduate							3	0.02	3	0.01
Total	30	100	30	%	15	100	139	100	214	100

Table 7 Respondents as to the Number of Years in Service

Number of Years	Lawyers		Psychologist		Priests/Laymen		Couples		Total
	f	%	f	%	f	%	f	%	f	%
31 years and above	3	0.1					29	0.13	32	0.14
26-30 years	12	0.4					16	0.04	28	0.13
21-25 years	2	0.07	7	0.23	4	0.27	21	0.08	34	0.16
16-20 years	3	0.1	10	0.33	8	0.53	16	0.11	37	0.17
11-15 years	2	0.07	8	0.27	3	0.2	20	0.14	33	0.15
6-10 years	3	0.1					30	0.28	33	0.15
1-5 years	5	0.17	5	0.17			7	0.26	17	0.08
Total	30	100	30	100	15	100	139	100	214	100

Table 8 Assessment of Love

Indicators	Lawyers		Psychologists		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The spouse shows love to his/her partner by serving the latter when he/she is at home.	4.40	VHO	4.00	VHO	3.73	HO	4.31	VHO	4.11	HO	4
2.     The spouse approves of making love to his/her partner regularly.	4.20	VHO	4.50	VHO	3.33	MO	3.81	HO	3.96	HO	8
3.     The spouse shows support on his/her partner’s ideas about the family.	4.20	VHO	4.60	VHO	3.80	HO	4.32	VHO	4.23	HO	2.5
4.     The spouse totally submits his/her life to his/her partner as a sign of his/her love with greater joy and commitment.	4.40	VHO	4.20	VHO	2.93	HO	4.21	VHO	3.94	HO	9
5.     The spouse looks up to his/her partner family with respect and dignity that deepens their sense of connection and strengthen their love to each other.	4.40	VHO	4.40	VHO	3.73	HO	4.39	VHO	4.23	VHO	2.5
6.     The spouse always wants to be with his/her partner.	4.20	VHO	4.20	VHO	3.73	HO	4.14	HO	4.06	HO	5.5
7.     The spouse is happy when he/she is with his/her partner  navigating the priorities in the family to ensure that their obligations do not overshadow the love they feel to each other.	4.20	VHO	4.40	VHO	3.66	HO	3.99	HO	4.06	HO	5.5
8.     The spouse talks to him/her about the plans with the family, career and future.	4.40	VHO	4.60	VHO	3.73	HO	4.43	VHO	4.29	VHO	1
9.     The spouse appreciates his/her partner in life because he/she meets the expectation on marrying him/her.	4.40	VHO	3.67	HO	3.60	HO	4.01	HO	3.92	HO	10
10.  The spouses share the wildest ideas to his/her spouse about fulfilling marital obligations and nurturing the love that brought them together in marriage.	4.60	VHO	4.00	HO	3.13	MO	4.23	VHO	3.99	HO	7
Overall Weighted Mean	4.34	VHO	4.24	VHO	3.56	HO	4.19	HO	4.08	HO

Table 9 Assessment of Financial Support

Indicators	Lawyers		Psychologists		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The spouses believed that financial support in a marriage is a shared responsibility, with both partners contributing resources, to maintain the household and meet the family’s needs.	4.40	VHO	4.60	VHO	3.93	HO	3.74	HO	4.17	VHO	7
2.     The spouses are fully aware that my partner’s salary is not enough for our expenses, hence, the other spouse contributes a portion of his/her salary to ease his/her partner’s financial burden	4.40	VHO	4.40	VHO	3.40	HO	4.41	VHO	4.15	VHO	8
3.     The spouses maintain an open communication and a commitment to fairness, considering each partner’s income and earning potential.	4.60	VHO	4.60	VHO	3.73	HO	4.44	VHO	4.34	VHO	1
4.     Money issues are not the primordial concerns in the family because the spouses regularly discuss financial status of the family.	4.40	VHO	4.40	VHO	3.0	HO	4.08	HO	3.97	HO	10
5.     Financial support often involves contributing to shared expenses like housing, utilities, groceries, and childcare, while working towards joint financial goals like retirement savings.	4.40	VHO	4.40	VHO	3.73	HO	4.33	VHO	4.21	VHO	6
6.     The spouses plan the financial obligations which include addressing individual needs and pre-existing debts, requiring communication and potential compromise.	4.40	VHO	4.60	VHO	3.93	HO	4.31	VHO	4.31	VHO	2.5
7.     The spouses maintain a level of financial independence, maintaining separate accounts while contributing proportionately to shared expenses.	4.20	VHO	4.40	VHO	3.33	HO	4.05	HO	3.99	HO	9
8.     When there is a financial problem, the spouses adjust financial support due to changes in income, job loss, or childcare, requiring flexibility and open communication.	4.40	VHO	4.40	VHO	4.0	HO	4.29	VHO	4.27	VHO	4
9.     The spouses discuss spending habits, the potential for large purchases, and debt management to maintain financial stability within the marriage.	4.40	VHO	4.40	VHO	4.20	VHO	4.25	VHO	4.31	VHO	2.5
10.  The spouse takes care of the children when his/her partner is busy with his/her work or household chores	4.40	VHO	4.40	VHO	3.93	HO	4.33	VHO	4.26	VHO	5
Overall Weighted Mean	4.40	VHO	4.46	VHO	3.72	HO	4.22	VHO	4.20	VHO

Table 10 Assessment of Living Together

Indicators	Lawyers		Psychologists		Priets/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The family lives in a habitable family home uninterruptedly.	5.00	VHO	4.60	VHO	4.06	HO	4.44	VHO	4.52	VHO	1
2.     The spouses establish their own boundaries and agreements surrounding finances, intimacy, and household duties.	4.40	VHO	4.40	VHO	3.66	HO	4.15	HO	4.15	HO	5
3.     The family acquired a family home to become the permanent abode for all of us.	4.80	VHO	4.40	VHO	3.73	HO	4.32	VHO	4.31	VHO	3
4.     The family structure follows the patriarchal system where the head of the family is the father.	4.20	VHO	4.60	VHO	3.66	HO	3.27	MO	3.93	HO	10
5.     The family observes close–knit relationships with one another.	4.40	VHO	4.60	VHO	3.86	HO	4.45	VHO	4.33	VHO	2
6.     The spouses ensure they do not argue in front of the children.	4.00	HO	4.00	VHO	3.60	HO	4.15	HO	3.94	HO	9
7.     The spouses’ welcome relatives from both sides of their family on special occasions as needed.	4.20	VHO	4.20	VHO	4.20	VHO	4.42	VHO	4.25	VHO	4
8.     The family is always together to address a pressing problem.	4.60	VHO	4.00	HO	3.66	HO	4.20	VHO	4.11	HO	6
9.     It is a practice in the family that when someone is not around, each member looks for him/her.	4.40	VHO	4.20	VHO	3.93	HO	3.79	HO	4.08	HO	7
10.  The spouses regularly talk even if there is no problem to keep abreast with their activities.	4.40	VHO	4.00	HO	3.80	HO	3.76	HO	3.99	HO	8
Overall Weighted Mean	4.44	VHO	4.30	VHO	3.82	HO	4.10	HO	4.16	HO

Table 11 Assessment on Fidelity

Indicators	Lawyers		Psychologists		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The spouses considered fidelity as a cornerstone of their marital obligations which fosters trust, intimacy, and security within the relationship.	4.73	VHO	4.40	VHO	4.40	VHO	4.49	VHO	4.50	VHO	1
2.     The spouse is attentive to the needs of his/her partner especially with his/her sexual needs to preserve the sanctity of their marriage.	4.20	VHO	4.60	VHO	4.13	HO	4.26	VHO	4.30	VHO	5
3.     The spouse is mindful about his/her marital vows.	4.40	VHO	4.60	VHO	4.20	VHO	4.49	VHO	4.42	VHO	2
4.     The spouses maintain an open communication as our key in establishing boundaries around acceptable behavior and emotional attachment outside the marriage.	4.60	VHO	4.20	VHO	4.13	HO	4.39	VHO	4.33	VHO	3.5
5.     When the spouses have disagreement on any matter especially on infidelity, they sit down to rebuild trust  through forgiveness and couple’s therapy	3.10	MO	3.60	VHO	4.06	HO	3.95	HO	3.68	HO	8
6.     When the spouse commits infidelity, the other party encourages him/her to share the feeling to address it constructively for the family’s benefit.	2.73	MO	3.00	MO	3.60	HO	3.66	HO	3.25	HO	10
7.     When a party is at fault because of his/her philandering activities, they talk about the issue  based on their  individual values.	3.00	MO	3.40	HO	3.53	HO	3.64	HO	3.40	HO	9
8.     The spouse always trust his/her partner about family matters.	4.20	VHO	4.40	VHO	4.33	VHO	4.41	VHO	4.33	VHO	3.5
9.     The spouse listens emphatically to his/her partner when he/she had done wrong.	4.20	VHO	4.40	VHO	3.60	HO	3.78	HO	3.99	HO	7
10.  In making an important decision in the family, the spouses communicate about the family’s priorities as a major consideration.	4.40	VHO	4.60	VHO	3.73	HO	3.78	HO	4.13	HO	6
Overall Weighted Mean	3.96	HO	4.12	HO	3.97	HO	4.08	HO	4.03	HO

Table 12 Summary of Assessments on Marital Obligations

Indicators	Lawyers		Psychologists		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
Love	4.34	VHO	4.24	VHO	3.56	HO	4.19	HO	4.08	HO	3
Financial Support	4.40	VHO	4.46	VHO	3.72	HO	4.22	VHO	4.20	VHO	1
Living Together	4.44	VHO	4.30	VHO	3.82	HO	4.10	HO	4.16	HO	2
Fidelity	3.96	HO	4.12	HO	3.97	HO	4.08	HO	4.03	HO	4
Overall Weighted Mean	4.29	VHO	4.28	VHO	3.77	HO	4.15	HO	4.12	HO

Table 13 Comparison of Assessments on marital obligations

Love
Source of Variance	SS	df	MS	F	CV	VI	Decision
Between	2.046	3	0.682	2.021	2.866	NS	Fail to Reject Ho
Within	12.146	36	0.337
Financial Support
Between	1.405	3	0.468	2.286	2.866	NS	Fail to Reject Ho
Within	6.780	36	0.188
Living Together
Between	1.205	3	0.402	2.530	2.866	NS	Fail to Reject Ho
Within	5.717	36	0.159
Fidelity
Between	0.200	3	0.067	0.245	2.866	NS	Fail to Reject Ho
Within	9.804	36	0.272

Table 14 Assessment on Severity

Indicators	Lawyers		Psychologists		Priests/laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The psychological incapacity of the spouse is apparent as when he becomes aggressive to the other party and the children.	2.30	LE	4.30	VHE	3.53	HE	3.09	ME	3.30	ME	2
2.     The party at fault is grossly ignorant of his/her essential marital obligations on the basic concepts of marriage, consent, and commitment.	2.40	LE	3.20	ME	3.53	HE	3.00	ME	3.03	ME	8
3.     The party at fault abandons the family without providing any financial support due to mental illness.	3.20	ME	3.20	ME	3.66	HE	2.92	ME	3.24	ME	4
4.     The party at fault poses an imminent danger of physical or emotional harm to the other partner or children.	3.60	HE	3.43	HE	3.33	ME	3.01	ME	3.34	ME	3.
5.     The party at fault maintains his/her paramour to the detriment of the family life without fulfilling the essential marital obligations rendering the marriage irreparable.	2.06	LE	3.07	ME	3.60	HE	2.95	ME	2.92	ME	10
6.     The party at fault becomes a significant factor affecting the well-being of the children from the marriage.	2.43	LE	3.43	HE	3.60	HE	3.08	ME	3.13	ME	5
7.     The party at fault perfected his/her vices on liquor, women, drugs, peers, and a lot more making the marriage dysfunctional to everyone.	2.30	LE	3.47	HE	3.53	HE	2.99	ME	3.07	ME	6.5
8.     The party at fault becomes pathological liar, deceitful, physically aggressive, stubborn to follow the norms of the society, impulsive, and shown reckless disregard to the safety of everybody.	2.37	LE	3.43	HE	3.66	HE	2.97	ME	3.01	ME	9
9.     The party at fault lacks remorse feelings to what he/had done to destroy the marriage bond.	3.73	ME	3.43	HE	3.73	HE	2.97	ME	3.47	HE	1
10.  The party at fault depicts consistent irresponsibility with his/her decisions and behaviors.	3.73	HE	3.43	HE	2.93	ME	2.44	ME	3.07	ME	6.5
Overall Weighted Mean	2.81	LE	3.44	HE	3.53	HE	2.94	ME	3.34	HE

Table 15 Assessment of Incurability

Indicators	Lawyers		Psychologist		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The psychological incapacity originates in the early years of development of the partner.	2.30	ME	4.30	VHE	3.53	HE	3.11	ME	3.31	ME	1
2.     Psychotherapy  of any kind would not help the party at fault to address the  psychological incapacity.	2.33	ME	3.20	HE	3.53	HE	2.92	ME	2.99	ME	10
3.     The party at fault is unaware of the existence of the psychological incapacity, thereby, unsusceptible to any kind of psychotherapy.	2.33	ME	3.20	HE	3.66	HE	2.88	ME	3.02	ME	6.5
4.     The psychological incapacity manifests during the subsistence of marriage	2.33	ME	3.43	HE	3.33	HE	3.00	ME	3.02	ME	6.5
5.     The psychological incapacity is recurring in the psyche of the party at fault.	2.80	MR	3.07	ME	3.60	HE	3.05	ME	3.13	ME	5
6.     Medical treatment is unavailable to the condition to the party at fault.	2.83	ME	3.43	HE	3.60	HE	2.87	ME	3.18	ME	2.5
7.     Marriage counseling is not feasible to the spouses.	3.00	MR	3.47	HE	3.53	HE	2.74	ME	3.18	ME	2.5
8.     The spouses are unmindful of their marital vows when they got married.	2.93	ME	3.43	HE	3.66	HE	2.68	ME	3.17	ME	4
9.     The cycle of psychological abuses is apparent in the relationship such as violation of the rights of the party, abandonment, dependency, consistent irresponsibility, impulsivity, reckless disregard to one’s safety and others.	2.93	ME	3.43	HE	3.73	HE	2.96	ME	3.26	ME	1
10.  The spouses’ psychological incapacity leads the children to become emotionally unstable about the family’s condition at home.	2.93	ME	3.43	HE	2.93	ME	2.81	ME	3.02	ME	6.5
Overall Weighted Mean	2.67	ME	3.44	HE	3.51	HE	2.90	ME	3.38	HE

Table 16 Assessment of Permanency

Indicators	Lawyers		Psychologist		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
1.     The psychological incapacity continues to endure in the person’s psyche, hindering the ability to fulfill marital obligations.	4.00	HE	3.36	ME	3.73	HE	2.81	LE	3.48	HE	6
2.     The psychological incapacity hinges on the limited potential for recovery.	4.20	VHE	2.53	LE	3.86	HE	2.81	LE	3.35	ME	8
3.     The psychological incapacity is characterized by frequent episodes with minimal or no improvement  at all.	4.20	VHE	3.20	ME	3.13	HE	2.76	LE	3.32	ME	9
4.     The psychological incapacity is based on the opinions of qualified mental health professions such as Psychiatrists and Psychologists regarding the long -term prognosis.	4.20	VHE	3.16	ME	3.13	HE	3.18	ME	3.42	HE	7
5.     The psychological incapacity leads the spouse to become irresponsible, insensitive, immature in  the performance of his/her essential marital obligations.	4.20	VHE	3.33	ME	4.06	HE	3.20	ME	3.70	HE	1
6.     The psychological incapacity is not readily seen during the courtship of the couple but becomes manifest during the marriage.	4.20	VHE	3.33	ME	3.53	HE	3.22	ME	3.57	HE	5
7.     The psychological incapacity makes the spouse at fault to become a complacent individual with his responsibility to the family.	4.20	VHE	3.33	ME	4.33	VHE	2.86	ME	3.68	HE	2
8.     The party in good faith depicts signs of the battered wife/battered husband syndrome where she/he remains loyal to the other party.	4.20	VHE	3.16	ME	2.93	ME	2.48	LE	2.40	LE	10
9.     The party at fault uses stealth and explosive power to subdue his/her partner for a period.	4.20	VHE	3.33	ME	3.73	HE	3.04	ME	3.58	HE	4
10.  The psychological incapacity is integrated into the personality system of the party at fault, who refused to seek treatment because he denied its existence.	4.20	VHE	3.33	ME	4.00	HE	3.12	ME	3.66	HE	3
Overall Weighted Mean	4.18	HE	3.21	HE	3.64	HE	2.95	ME	3.50	HE

Table 17 Summary of Assessments on Psychological Incapacity

Indicators	Lawyers		Psychologist		Priests/Laymen		Couples		Composite		Rank
	WM	VI	WM	VI	WM	VI	WM	VI	WM	VI
Severity	2.81	LE	3.44	HE	3.53	HE	2.94	ME	3.34	HE	3
Incurability	2.67	ME	3.44	HE	3.51	HE	2.90	ME	3.38	HE	2
Permanency	4.18	HE	3.21	HE	3.64	HE	2.95	ME	3.50	HE	1
Overall Weighted Mean	3.22	ME	3.36	ME	3.56	HE	2.93	ME	3.41	HE

Table 18 Significant Relationship between Marital obligations and Psychological Incapacity

Indicator	r  values	VI	t-value	VI	Decision
Love	0.93	VHC	7.156	S	Reject Ho
Financial Obligation	0.89	VHC	5.521	S	Reject Ho
Living Together	0.91	VHC	6.208	S	Reject Ho
Fidelity	0.86	VHC	4.767	S	Reject Ho

DISCUSSION

Table 1 shows the frequency distribution of the respondents as to category. It revealed that there were 30 lawyers; 30 Psychologists; 15 priests/laymen; and 139 couples who were the respondents of the present study.

As revealed in table 2, there were thirty 30 lawyers who belonged to the legal profession; 30 psychologists who belonged to the professional helpers; 15 religious groups; and one hundred thirty-nine (139) of the couples in Metro Manila.

Table 3 projects the respondents as to age.  As projected in the table, majority of the respondents across the four (4) groups of respondents belonged to the age brackets of 41-45 and 46-50 with 50 and 48 ages respectively.

Table 4 depicts that there are 131 female and 83 male respondents.  There was a great number of female respondents who participated in the study.

Table 5 exhibits data of the respondents as to civil status.  There were 124 married participants; 64 singles; 14 legally separated; and 12 widow/widower.

Table 6 manifests the data of the respondents as to educational attainment.  There were 60 respondents who finished their bachelor’s degree; 50 with doctorate degrees; 45 with master’s degrees; 41with master’s units; 15 with doctorate degree units; and 3 who were undergraduate.

Table 7 gleans the data of the respondents as to the number of years in service.  As gleaned in the table, there were 3 lawyers with 31 years and above years length of service; 12 with 26-30 years; 2 with 21-25 years; 3 with 16-20 years; 2 with 11-15 years; 3 with 6-10 years; and 5 with 1-5 years.

On the assessment of love in Table 8, the lawyers and psychologists rated this variable as Very Highly Observed with 4.34 and 4.24 weighted mean values while priests/laymen and couple rated it as Highly Observed with 3.56 and 4.19 weighted mean values respectively.  The four groups of respondents were consistent in their assessment about love as a marital obligation of the spouses in the marriage.

This finding is supported by Sanchez (2016) when he said that marital obligations, under the law, include loving each other, showing support, living together and becoming loyal to each other.  It can be deduced that all the marital obligations are, indeed, significant in the preservation of marriage as it is defined in the Constitution of the Philippines where “marriage is an inviolable social institution”.

Table 9 exhibits the assessment of marital obligations based on the financial support of the couple with 4.40; 4.46; 4.22 as Very Highly Evident and 3.72 as Highly Evident obtained weighted means. The respondents were unanimous in their assessment of financial support except in the case of priests/laymen who assessed it with a little lower than the three groups: lawyers, psychologists, and couples.  As a whole, the respondents are in agreement with the financial support to be a shared responsibility of the couple in marriage.

The finding supports the contention of Mamangun who identified that the essential marital obligations of either or both spouses to the marital union include the obligation to live together as husband and wife, to observe mutual love, respect and fidelity, and to provide support to each other.

Table 10 reveals the assessment of the respondent as to the marital obligations of the couple to live together.

On the assessment of the marital obligation to live together, the results of the four groups of respondents provided a robust foundation for a marriage where the couple are expected to be in a roof with their beloved one and children with 4.44; 4.30; 3.82; and 4.10 weighted means verbally interpreted as Very Highly Observed to Highly Observed.  A couple who does not live together may become remiss in their marital obligation as when they ignore vehemently their responsibility to support financially the family and every member of it.

The present finding is supported by Cornelio (2018) when he said that “Marriage is perceived as purely commitment and love between two (2) couples bound to live together until death, giving it its sacredness (Times of India, 2023).  With this concept, marriage is viewed as a “heaven-created” union (Cornelio), 2018) that it influences attitudes towards annulment, and not divorce as it ends a marriage, which can affect the child inside the created relationship and the societal views on the persons between that marriage (Government of Canada, 2022).

Table 11 projects the assessment of marital obligations on fidelity by the respondents.

It was observed that the assessment of the four groups of respondents do not significantly differ from each other.  There was a slight difference with each other though.  However, taken holistically, the respondents provided synchronous results that the couple are expected to live together in building their family and conjugal life in the community with weighted means of 3.96; 4.12; 3.97; and 4.03 all verbally interpreted as Highly Observed.

The finding is supported by Dhuli (2024) where he said that marriage, as an institution of law, is based on the moral and legal equality of spouses, on feeling of mutual love, respect, and understanding, as the basis of family unity. Healthy family and marital relationships contribute to the elimination of gender stereotypes.  It all starts in the family and is transmitted throughout society.

Table 12 reveals the summary of assessments on marital obligations.

Looking at the summary of assessments on marital obligations, the lawyer and psychologist respondents have a high assessment as to the four components of the marital obligations with the overall weighted means of 4.29 and 4.28 for love, financial support, living together, and fidelity while the priests/laymen and couples have a slight assessment with 3.77 and 4.15 respectively for the four components of marital obligations.

Analyzing the assessment made by the group of respondents will provide a favorable contention of them as to the marital obligations.  There is no significant difference as they all believed that the four components are the foundations of a relation which give rise to the intention of a sacred relationship called marriage.

Comparing the assessments of the four groups of respondents on marital obligations in Table 13 resulted in F values of 2.02 for love, 2.29 for financial obligations, 2.53 for living together, and 0.25 for fidelity.

These results fell below the critical F value of 2.866 at 0.05 level of significance, verbally interpreted as not significant, failing to reject the null hypothesis that there is no significant difference in the assessments of the lawyers, psychologists, couples, and priests /laymen on marital obligations.

This shows that the respondents have similar assessments of the marital obligations of husband and wife or anyone in a similar relationship.

Marital obligations are the cornerstones of a healthy and fulfilling marriage. They encompass both legal and emotional commitments that bind spouses together. These obligations include living together, fostering mutual love and respect, and providing emotional and financial support. Fulfilling these obligations creates a sense of security, stability, and trust within the marriage. It allows couples to weather life’s challenges together and build a strong foundation for their relationship. However, marital obligations are not a one-way street. They require constant effort, open communication, and a willingness to compromise from both partners. When these obligations are met with understanding and compassion, they can lead to a deeply satisfying and enriching partnership.

Table 14 depicts the assessment of the psychological incapacity as to severity.

The assessment of the four (4) groups of respondents underscores a robust foundation of their professional backgrounds.  The respondents differ with the assessment with weighted means of 2.81 and 2.84 for lawyers and couples verbally interpreted as Moderately Evident; and 3.44 and 3.53 for psychologists and priests/laymen respectively verbally interpreted as Highly Evident.  and 2.84 for couples verbally interpreted as Moderately Evident.  They, therefore, believed that psychological incapacity be grave with no available medical or psychological intervention of any kind that can be used to cure it.

To highlight the findings, in the Republic of the Philippines v. Liberato P. Mola Cruz (G.R. No. 236629, July 23, 2018), the Court explained that the psychological incapacity must be shown to be appreciated in its totality where any medical or behavioral treatment of the identified disorder of the party would prove to be ineffective.

Table no. 15 reveals the assessment of psychological incapacity as to incurability.

The assessment of incurability of the psychological incapacity implies that the said element is embedded in the personality structure that incapacitated the person from accepting any therapy or intervention in complying with the obligations in marriage with weighted means of 2.67 and 2.90 for lawyers and couples respectively and 3.44 and 3.51 for the psychologists and priests/laymen.  The parties must understand the psychological incapacity must be in a state of extreme insusceptible to any medicine or treatment. Although there are slight variations in specific indicators, the overall assessment remains grounded emphasizing that the psychological incapacity be that it must be in its worst condition.

The finding was supported by the article published by Anarma Law Firm (2021) on Supreme Court’s summary of the amendment to psychological incapacity was discussed.  The High Court contended that psychological incapacity involves a clear dysfunctional behavior that demonstrated a lack of understanding and compliance with essential marital obligations due to psychological causes.  Further, the incapacity must exist at the time of marriage and stem from a persistent aspect of one’s personality that was formed before marriage.

Table 16 gleans the assessment of permanency of the psychological incapacity.

The assessment of permanency of the psychological incapacity implies a generally acceptable attitude on this element with weighted means of 4.18; 3.21 and 3.84 verbally interpreted as Highly Evident and 2.95 verbally interpreted as Moderately Evident.   It is a condition that is not physical but mental in nature, such that either or both spouses would be truly incognizant to assume and discharge their essential marital obligations.

The doctrinal case of Santos v. Court of Appeals supported the findings that said condition must be grave, incurable, and with juridical antecedents.  The latter pertains to the nature of the psychological incapacity which emanated during his developmental years like a pathogenic parental model.

Table 17 presents the summary assessment on psychological incapacity.

Comparing the assessment of the respondents on the psychological incapacity provided data that the priests/laymen rat got a weighted mean of 3.58 verbally interpreted as Highly Evident while the lawyer, psychologist and couple respondents assessed the components of psychological incapacity with weighted means of 3.22, 3.36 and 2.93 all verbally interpreted as Moderately Evident.

The composite means of the assessment of the four groups of respondents gave rise to 3.34 for severity; 3.38 for incurability, and 3.50 for permanency, all verbally interpreted Highly Evident

It can be deduced from the above data that there was a slight difference on the assessment of the lawyers compared with the three other respondents.  Taking their assessment as a whole, it could be gleaned that they are all legalistic in their assessment as to the components of the psychological incapacity which may impact the relationships of the couple.  The three groups of respondents, however, had more or less, similar assessments of the different components of psychological incapacity.

Table 18 correlated marital obligations and psychological incapacity resulted in r values of 0.93 for love, 0.89 for financial obligations, 0.91 for living together, and 0.86 for fidelity. These results indicate a very high correlation between psychological incapacity and marital obligation.

This shows that marital obligations and psychological incapacity are intricately linked. Marital obligations encompass the essential duties of marriage, like cohabitation, fidelity, and emotional support.  Psychological incapacity, on the other hand, refers to a severe mental or personality condition that prevents a person from fulfilling these obligations.

CONCLUSIONS

The following conclusions are hereby made:

1. That the concept of marital obligations provides a strong fortress for a stable and satisfying relational life between couples. They must perform these marital obligations to guarantee the continuance of marriage which is protected by the fundamental law of the land in the Philippines. Moreover, marital obligations are evolving and lifelong commitments where a shared responsibility, open communication, and a willingness to be flexible will guarantee healthy and happy relations between couples in the marriage;
2. That people, in general, have similar perspectives on marital obligations especially those from the same cultural orientations such as in the Philippines. Thus, a person who is capacitated to enter into a relationship such as marriage should have a deeper understanding of one’s responsibility in deterring the occurrence of psychological incapacity;
3. That psychological incapacity, when demonstrably permanent, severe, and incurable, can have a devastating effect on an individual’s ability to enter into a fulfilling and healthy marriage. Destigmatizing psychological incapacity and encouraging individuals to seek professional help is significantly necessary to improve a person’s well-being and offer him the opportunity to establish healthy relationships with his/her partner in the future;
4. That while societal expectations play a role in marital obligations, individuals must have the flexibility to define their partnership and function. Similarly, recognizing psychological incapacity helps separate genuine challenges from societal pressures; and
5. That psychoeducational workshop on modern relationships may be conducted defining expectations, communication skills, conflict resolution, and navigating changing roles within a marriage.

REFERENCES

A. Books

1. Calmorin, Laurentina (2019) Research and Statistics with Computer. Quezon City: National Bookstore. ISBN 971-08-7097
2. Santrock, John W. Life-Span Development. New York: McGraw-Hills Companies, Inc., 2017.  14^th

B. Journals/Periodicals

B.1 Journals

1. Abalos, J. (2017, May 9). Divorce and Separation in the Philippines: Trends and correlates. Demographic Research
2. Adekile, Oluwakem. Mental and Physical Incapacity as Issues Affecting the Legality of Marriage in Nigeria –   A Critical Examination. https//ssm.com/abstract=3111166
3. Arias, A. R. V., Jr. (n.d.). A thematic look at selected cases of marital nullity in the Philippines. IAFOR Journal of Psychology & the Behavioral Sciences. https://iafor.org/archives/journals/iafor-journal-of-psychology-and-the-behavioral-sciences/10.22492.ijpbs.2.3.05.pdf
4. Arzeen, Salma, Arzeen, Naeema & Muhammad, Hayat, The Relationship between Marital Satisfaction and Psychological well-being in Couples: The Role of Gratitude as a Moderator 2023.
5. Bautista, C. M. (2020). BARGAINING LEVERAGE IN FAMILY PLANNING: A GENDER-BASED ANALYSIS OF FILIPINO COUPLES’ REPRODUCTIVE CHOICES. International Journal for Studies on Children, Women, Elderly and Disabled, 9(ISSN 0128-309X). https://www.ijcwed.com/wp-content/uploads/2020/04/PICCWED9 11.pdf
6. Buda Dhulı, B., & Dhulı, E. (2024). Marriage and the Obligations Arising from It. Interdisciplinary Journal of Research and Development, 11(1 S1), 201. https://www.journal-uamd.org/index.php/IJRD/article/view/397
7. Choi KH, Catania JA, Dolcini MM. Extramarital sex and HIV risk behavior among US adults: results from the National AIDS Behavioral Survey. American Journal of Public Health. 1994;84, 2003-2007.
8. Cynkier, Przemyslaw. Psychological Impediments to Marriage – Forensic and Psychiatric Opinions. Part II.  Pol. 2020; 54(1): 163-175
9. Ensuring Women’s Equal Rights in Marriage and Family Relations: Amending Articles 14, 19, 124,
10. Fact Sheet on Marriage in Switzerland: Rights and Obligations. Deferral Department of Justice and Police FDJP 2020
11. Fatima, M., & Ajmal, M. A. (2012). Happy marriage: A qualitative Study. Pakistan Journal of Social and Clinical Psychology, 10(1), 37-42. Retrieved from https://www.gcu.edu.pk/pjscp.php?pg=previous-issues
12. Franco, Maria Katrina C. The Psychological Incapacity of Mary Critical Jurisprudence and Survey of Cases from 1995-2019 M IBP Journal UP WILOCI (WOMEN’S LAWYERS’CIRCLLE, INC) 75-anniversary Edition Vol/ 46 Issue no. 1 March 2021
13. Gorecho, D. (2021, May 20). Psychological incapacity and nullity of marriage cases. Panay News. https://www.panaynews.net/psychological-incapacity-and-nullity-of-marriage-cases/https://www.panaynews.net/psychological-incapacity-and-nullity-of-marriage-cases/
14. Khan, Luthfa and Suzanne Wilson. (2019). Understanding mental capacity and marriage. https://respond.org.uk/wp-content/uploads/2019/06/7-Respond-Mental-Capacity-Booklet-A5-28pp LR.pdf
15. Luryi, Y. (2024). Rights and Obligations of Spouses, 10-2 Manitoba Law Journal 149 https://www.canlii.org/en/commentary/doc/1979CanLIIDocs88#!fragment/zoupio- Tocpdf bk 2/ BQCwhgziBcwMYgK4DsDWszIQewE4BUBTADwBdoAvbRABwEtsBaAfX2zhoBMAzZgI1TMATAEoANMmylCEAIqJCuAJ7QA5KrERCYXAnmKV6zdt0gAynlIAhFQCUAogBl7ANQCCAOQDC9saTB80KTsIiJAA
16. Mark KP, Janssen E, Milhausen RR. Infidelity in heterosexual couples: Demographic, interpersonalCranefield, I. (2022, April 4). Marriage and Capacity: When Consent Isn’t Enough. Richard Nelson LLP. https://www.richardnelsonllp.co.uk/marriage-and-capacity/
17. Nawaz, Salma I, Kiran, Ayesha, Shabbir, Malik Shahzad Shabbir, Koser, Mouna, & Zamir Aysha. A Study to analyze the Rights and Responsibilities of Husband and Wife Relationship in Pakistan.  Pakistan Journal of Multidisciplinary Research (PJMR) Vol. 3 IssueI, June 2022.
18. Onesa, A. G., & Vargas, D. (2022). View of roles and influence of the farmers’ wives in farming activities and credit availed in the Philippine’s rural communities. https://journalppw.com/index.php/jpsp/article/view/13237/8596
19. Percival, Abarquez Salting Commission on Population and Development, Welfareville Compound, Mandaluyong City, Philippines
20. Prasetya, B, E, A (2007). Wife’s Perception of Husband’s Support in Pursuing Her Career about Wife’s Marital Satisfaction among Working Wives in Metro Manila, Faculty of Psychology, Satya Wacana Christian University, P 3-4. Qadir, F., de Silva P., Prince, M. and Khan’ M. (2005). Marital satisfaction
21. Raul, Umara, Fatima, Hamile, & Mushtaq, Muazma. Distress Tolerance, Mental Health Problems, and Marital Satisfaction among Married Couples.  Pakistan Journal of Social Research.  2023
22. Ricafrente, Jellian R. Torres. CASE ANALYSIS OF ANNULLED WOMEN and their MANNER in MOVING International Journal of Arts, Sciences and Education Vol 3 Issue June 2022
23. Robles, Eufemia L. and Sarcon, Leigh, the Mediating Effect of Work Commitment on the Relationship between Family and Marital Satisfaction of Social Workers” University of Mindanao, Philippines. European Journal of Education Studies Vol 10, Issue 8 2023
24. Salting, P. A. (2020). Women empowerment and its relationship to spousal violence: Evidence from the 2017 Philippines National Demographic and Health Survey. 2020 Asia–Pacific Statistics Week. https://www.unescap.org/sites/default/files/51 Women Empowerment and its Relationship to Spousal Violence Philippines.pdf
25. Sanchez, Richard D. Unveiling the Moral Theological Foundations of the Nullity of Marriage Due To Psychological Incapacity. Manila. 2017.
26. Siva, Nambi & Sarkar, Siddharth. Mental Illness and Nullity of Marriage: Indian Perspective. Indian Journal of Psychological Medicine July-Sep- 2015 Vol. 37 Issue 3
27. Su-Yeon Choi, Hyoung-Ryoul Kim 2 and Jun-Pyo Myong. The Mediating Effects of Marital Intimacy and Work Satisfaction in the Relationship between Husbands’s Domestic Labor and Depressive Mood of Married Working Women. International Journal of Environmental Research and Public Health.  2020
28. Weinberg, R. (2024) The Endless Umbilical Cord: Parental Obligation to Grown Children |  Journal of Practical Ethics, n.d.) https://www.jpe.ox.ac.uk/papers/the-endless-umbilical-cord-parental-obligation-to-grown-children/
29. Women Empowerment and its Relationship to Spousal Violence: Evidence from the 2017 Philippines National Demographic and Health Survey 2020 Asia–Pacific Statistics Week A decade of action for the 2030 Agenda: Statistics that leaves no one and nowhere behind 15-19 JUNE 2020 | Bangkok, Thailand
30. Yeun YR, Yang S. Effects of a marital relationship enrichment program on communication, conflict resolution, and marital satisfaction in multicultural couples. J Korean Acad Psychiatr Ment Health Nurs. 2012;21(3):250–61.

 B.2 Periodicals

1. Article published by Inquirer.Net (2021),
2. Article published by Anarna Law Firm (2021),
3. Article published by Inquirer.Net (2023)
4. Article by The Philippine Star (2022)
5. Philippine Daily Inquirer (2015),
6. JobStreet.com

C. Legal Materials

1. Department of Health (DOH) 2020 Family Code of the Philippines
2. Philippine Constitution of the Philippines Philippine Statistics Authority 2020
3. UNICEF REPORT 2020
4. Family Code of the Philippines of 1987 Santos v. Court of Appeals
5. The Republic of the Philippines v. Chi Ming Tsoi v. Court of Appeals 2018
6. The Republic of the Philippines v. Liberato P. Mola Cruz (G.R. No. 236629, July 23, 2018)
7. Maria Teresa B. Tani – De La Fuente v. Rodolfo De laFuente, Jr. (G.R. No. 188400, March 8, 2017),