Republic v. Molina, G.R. No. 108763, Feb. 13, 1997

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REPUBLIC OF THE PHILIPPINES, petitioner, vs.

COURT OF APPEALS and


RORIDEL OLAVIANO MOLINA, respondents.

G.R. No. 108763 February 13, 1997

FACTS:

The case at bar challenges the decision of CA affirming the marriage of the respondent
Roridel Molina to Reynaldo Molina void in the ground of psychological incapacity. The
couple got married in 1985, after a year, Reynaldo manifested signs of immaturity and
irresponsibility both as husband and a father preferring to spend more time with friends
whom he squandered his money, depends on his parents for aid and assistance and was
never honest with his wife in regard to their finances. In 1986, the couple had an
intense quarrel and as a result their relationship was estranged. Roridel quit her work
and went to live with her parents in Baguio City in 1987 and a few weeks later, Reynaldo
left her and their child. Since then he abandoned them.

ISSUE:

Whether or not the marriage is void on the ground of psychological incapacity.

HELD:

The marriage between Roridel and Reynaldo subsists and remains valid. What
constitutes psychological incapacity is not mere showing of irreconcilable differences
and confliction 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.

The following are the guidelines as to the grounds of psychological incapacity laid set
forth in this case:

burden of proof to show nullity belongs to the plaintiff


root causes of the incapacity must be medically and clinically inclined
such incapacity should be in existence at the time of the marriage
such incapacity must be grave so as to disable the person in complying with the
essentials of marital obligations of marriage
such incapacity must be embraced in Art. 68-71 as well as Art 220, 221 and 225
of the Family Code
decision of the National Matrimonial Appellate Court or the Catholic Church must
be respected
court shall order the prosecuting attorney and the fiscal assigned to it to act on
behalf of the state.

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