Republicv.Molina,G.R.No.

108763
February13,1997
FACTS: Roridel and Reynaldo were married on April 14, 1985 and begot a
son. After a year of marriage, Reynaldo showed signs of "immaturity and
irresponsibility" as a husband and a father since 1) he preferred to spend
more time with his peers and friends on whom he squandered his money;
2) he depended on his parents for aid and assistance; and 3) he was never
honest with his wife in regard to their finances, resulting in frequent
quarrels between them. When Reynaldo was relieved from his job, Roridel
had been the sole breadwinner of the family. In October 1986 the couple
had a very intense quarrel, as a result of which their relationship was
estranged. In March 1987, Roridel resigned from her job in Manila and
went to live with her parents in Baguio City. A few weeks later, Reynaldo
left Roridel and their child, and had since then abandoned them. Reynaldo
admitted that he and Roridel could no longer live together as husband and
wife, but contended that their misunderstandings and frequent quarrels
were due to (1) Roridel's strange behavior of insisting on maintaining her
group of friends even after their marriage; (2) Roridel's refusal to perform
some of her marital duties such as cooking meals; and (3) Roridel's failure
to run the household and handle their finances. On 16 August 1990,
Roridel filed a petition for declaration of nullity of her marriage to Reynaldo
Molina. Evidence for Roridel consisted of her own testimony, that of two of
her friends, a social worker, and a psychiatrist of the Baguio General
Hospital and Medical Center. Reynaldo did not present any evidence as he
appeared only during the pre-trial conference. RTC declared the marriage
void. The Solicitor General appealed to the Court of Appeals. The Court of
Appeals denied the appeals and affirmed in toto the RTCs decision.
Hence, this petition.
ISSUE: W/N psychological incapacity on the part of Reynaldo has been
established
HELD: The marriage between Roridel and Reynaldo subsists and remains
valid. What constitutes psychological incapacity is not mere showing of
irreconcilable differences and conflicting personalities. It is indispensable
that the parties must exhibit inclinations which would not meet the
essential marital responsibilities and duties due to some psychological
illness. Reynaldos action at the time of the marriage did not manifest such

characteristics that would comprise grounds for psychological incapacity.

The evidence shown by Roridel merely showed that she and her husband
cannot get along with each other and had not shown gravity of the problem
neither its juridical antecedence nor its incurability. In addition, the expert
testimony by Dr Sison showed no incurable psychiatric disorder but only
incompatibility which is not considered as psychological incapacity.
8 Guidelines (Psychological Incapacity)
1. The burden of proof to show the nullity of the marriage belongs to the
plaintiff.
2. The root cause of the psychological incapacity must be (a) medically or
clinically identified, (b) alleged in the complaint, (c) sufficiently proven by
experts and (d) clearly explained in the decision.
3. The incapacity must be proven to be existing at "the time of the
celebration" of the marriage.
4. Such incapacity must also be shown to be medically or clinically
permanent or incurable
5. Such illness must be grave enough to bring about the disability of the
party to assume the essential obligations of marriage.
6. The essential marital obligations must be those embraced by Articles 68
up to 71 of the Family Code as regards the husband and wife as well as
Articles 220, 221 and 225 of the same Code in regard to parents and their
children.
7. Interpretations given by the National Appellate Matrimonial Tribunal of
the Catholic Church in the Philippines, while not controlling or decisive,
should be given great respect by our courts.
8. The trial court must order the prosecuting attorney or fiscal and the
Solicitor General to appear as counsel for the state.