Republic of the Philippines vs Court of Appeals and Molina

G.R. No. 108763 February 13, 1997

FACTS:
Roridel and Reynaldo were legally married on April 14, 1985 at the Church of St.
Augustine, Manila
Out of their marriage, a child named Albert Andre Olaviano Molina was born on July
29, 1986.
After a year of marriage, Reynaldo showed signs of "immaturity and irresponsibility"
as a husband and a father resulting in frequent quarrels between them.
In March 1987, Roridel resigned from her job in Manila and went to live with her
parents in Baguio City and a few weeks later, Reynaldo left Roridel and their child,
and had since then abandoned them.
Roridel filed with the Regional Trial Court of La Trinidad, Benguet to declare their
marriage void on the ground of "psychological incapacity" under Article 36 of the
Family Code.
On May 14, 1991, the trial court rendered judgment declaring the marriage void.
The appeal of petitioner was denied by the Court of Appeals which affirmed in toto
the RTC's decision.
Reynaldo then filed a petition for review on certiorari challenging the Decision of the
Court of Appeals
ISSUE:
Whether or not the marriage is void under the ground of psychological incapacity
HELD:
Applying Leouel Santos, the court ruled to grant the petition. The assailed decision
was reversed and set aside. The marriage of Roridel Olaviano to Reynaldo Molina
subsists and remains valid.
In Leouel Santos vs. Court of Appeals the Court, speaking thru Mr. Justice Jose C.
Vitug, ruled that "psychological incapacity should refer to no less than a mental (nor
physical) incapacity and that there is hardly any doubt that the intendment of the
law has been to confine the meaning of 'psychological incapacity' to the most
serious cases of personality disorders clearly demonstrative of an utter insensitivity
or inability to give meaning and significance to the marriage.
The following are the guidelines as to the grounds of psychological incapacity laid
set forth in this case:
1.
2.
3.
4.
5.

Burden of proof to show nullity belongs to the plaintif

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 should be medically or clinically permanent or incurable
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

6. Decision of the National Matrimonial Appellate Court or the Catholic Church

must be respected
7. Court shall order the prosecuting attorney and the fiscal assigned to it to act
on behalf of the state.