The Supreme Court’s ruling in Chan Tee Ten v. Tee Ten (G.R. No. 259322, 6 August 2025) offers an important occasion to reflect on how controlling and domineering conduct may be appreciated under Article 36 of the Family Code. The decision reinforces a doctrinal lens through which such conduct may, in proper cases, rise to the level of psychological incapacity.
Article 36 has never been intended as a remedy for ordinary marital friction. The Court has consistently held that personality clashes, emotional immaturity, or even domineering tendencies do not automatically constitute psychological incapacity. What the law addresses is a condition so serious and enduring that it renders a spouse genuinely incapable of understanding and performing the essential obligations of marriage.
In this context, controlling and domineering conduct must be carefully distinguished from mere assertiveness or marital dominance. The decision reminds us that the focus is not on the label attached to the behavior, but on its effect. When control becomes pervasive, inflexible, and deeply ingrained — so much so that it negates mutual respect, shared decision making, and emotional reciprocity — it may be symptomatic of a psychological condition contemplated by Article 36.
The Court’s approach emphasizes function over form. Psychological incapacity is determined not by the presence of a clinical diagnosis alone, but by whether the conduct demonstrates an inability, rather than a refusal, to comply with marital obligations. Controlling behavior, when shown to be compulsive, pre-existing and resistant to change, may reflect such inability. It is this incapacity to relate as an equal partner — not the mere exercise of control — that the law seeks to address.
Equally significant is the Court’s treatment of expert evidence. Chan Tee Ten v. Tee Ten reiterates that psychological incapacity may be established through the totality of evidence, even in the absence of a personal psychological examination. What matters is that expert opinions are firmly anchored on proven facts and are consistent with the parties’ conduct before and during the marriage. This allows courts to evaluate controlling behavior within a structured, evidentiary framework rather than through subjective impressions.
Properly understood, the decision does not lower the threshold for nullity. It cautions courts against mechanically equating control with incapacity. Instead, it requires a showing that the controlling conduct is a manifestation of a grave psychological condition existing at the time of the marriage and continuing thereafter. Absent this nexus, control remains a marital problem, not a legal ground for nullity.
The constructive value of the ruling lies in its balance. It protects the institution of marriage by preserving the narrow scope of Article 36, while recognizing that some marriages fail not because spouses will not perform their duties, but because one of them cannot.
When controlling conduct reflects such inability, the law does not punish failure; it acknowledges incapacity. This principled interpretation ensures that Article 36 remains a remedy of last resort, grounded on law, evidence and judicial restraint, not on the spouse’s mere intention to get out of the marriage.
Properly understood, the decision strengthens, rather than weakens, the institution of marriage. It discourages casual reliance on Article 36 while protecting spouses trapped in unions where control replaces companionship. When applied with discipline and sensitivity, the doctrine ensures that marriage remains a partnership of equals, grounded on dignity and mutual respect.
