Republic vs CA and Molina (G.R. No.

108763)

PANGANIBAN, J.:

Facts:

Roridel Olaviano was married to Reynaldo Molina on 14 April 1985 in Manila, and gave birth to a son a
year after. Reynaldo showed signs of “immaturity and irresponsibility” on the early stages of the
marriage, observed from his tendency to spend time with his friends and squandering his money with
them, from his dependency from his parents, and his dishonesty on matters involving his finances.
Reynaldo was relieved of his job in 1986, Roridel became the sole breadwinner thereafter. In March
1987, Roridel resigned from her job in Manila and proceeded to Baguio City. Reynaldo left her and their
child a week later. The couple is separated-in-fact for more than three years.

On 16 August 1990, Roridel filed a verified 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. On 14 May 1991, the trial court rendered
judgment declaring the marriage void. The Solicitor General appealed to the Court of Appeals. The Court
of Appeals denied the appeals and affirmed in toto the RTC’s decision. Hence, the present recourse.

ISSUE: Whether opposing or conflicting personalities should be construed as psychological incapacity

RULING:

No. There is no clear showing to us that the psychological defect spoken of is an incapacity; but appears
to be more of a “difficulty,” if not outright “refusal” or “neglect” in the performance of some marital
obligations. Mere showing of “irreconcilable differences” and “conflicting personalities” in no wise
constitutes psychological incapacity.

The Court, in this case, promulgated guidelines in the interpretation and application of Article 36 of the
Family Code: 1) The burden of proof to show the nullity of marriage belongs to the plaintiff; 2) the root
cause of PI must be (a) medically or clinically identified (b) alleged in the complaint (c) sufficiently proven
by experts (d) clearly explained in the decision; 3) it must be existing at the time of the celebration of the
marriage; 4) it must be medically or clinically permanent or incurable; 5) it must be grave enough to
bring about the disability of the party to assume the marital obligations of marriage; 6) the marital
obligations must be embraced by Articles 68 to 71, and Articles 220, 221 and 225 in regard of parents
and their children; 7) interpretation by the National Appellate Matrimonial Tribunal of Catholic of Church
of the Philippines, although not binding, should be given great respect; and 8) the prosecuting attorney
or fiscal and the Solicitor General must appear as counsel for the State.