REPUBLIC V MOLINA

GR no. 108763
February 13,1997
Ponente: Panganiban, J.

FACTS
Roridel Molina, respondent, filed a verified petition for declaration of nullity of her marriage to Reynaldo Molina
on August 16, 1990. The said petition alleged the solemnization of their marriage on April 14, 1985 and that a
son, Andre Molina was born. It was also claimed that after a year of marriage, Reynaldo showed the following
signs of "immaturity and irresponsibility" as a spouse and a father: he spent more time with his peers whom he
squandered his money, depended on his parents for assistance and lied to his wife about their finances
causing quarrels between them. He even lost his job which put all the financial responsibilities on Roridel's
shoulders. After an intense quarrel, Roridel left Manila to live with her parents in Baguio. Reynaldo had
abandoned the family a few weeks later. The said petition claimed that these signs show Reynaldo is
psychologically incapable of complying with essential marital obligations thus their marriage has to be declared
null and void.
Reynaldo's Answer, despite admitting that both of them can't live together anymore, contended that their
quarrels were actually caused by his wife's strange behavior.
The RTC declared the marriage void and an appeal of the petitioner was denied by the CA, hence, the present
recourse.

ISSUE
WON opposing or conflicting personalities constitute psychological incapacity.

HELD
No. There is no clear showing that the psychological defect spoken of is an incapacity. It appears to be more
of a “difficulty” if not outright “refusal” or “neglect” in the performance of some marital obligations.
From the Court's own deliberations, the following guidelines in the interpretation and application of Art. 36 of
the Family Code were established: 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.
The petition is granted.