April 10, 2011

Republic vs CA and Molina

Republic vs. CA and Molina
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 responsibilites and duties due to some psychological illness.  Reynaldo’s 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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