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Republic of the Philippines v.

CA and Molina
G.R. No. 108763
February 13, 1997
Panganiban, J.
Respondent Roridel Molina married Reynaldo Molina on April 14, 1985. After a year of marriage,
Reynaldo showed signs of immaturity and irresponsibility as a husband and a father exhibited by his
preference to spend time with friends, squandering money, dependence on his parents and dishonesty
involving finances. Inevitably, this resulted in quarrels and by March 1987, Roridel quit her job and
moved in with her parents in Baguio. Reynaldo left her and their child a few weeks thereafter.
On Aug. 16, 1990, Roridel filed a verified petition for declaration of nullity of marriage on the
grounds of psychological incapacity of the husband. The trial court declared the marriage void, which
the CA affirmed in toto; hence, the petition for certiorari.
Whether there is psychological incapacity
No. The case of Roridel and Reynaldo merely constituted incompatibility among the estranged
spouses. The law intended to confine the meaning of psychological incapacity only to the most serious
cases of personality disorders that must have existed at the time marriage is celebrated. Irreconcilable
differences or conflicting personalities are not incapacities that would hinder the fulfillment of the
essential marital obligations of the parties. The characteristics of gravity, judicial antecedence and
incurability are not present in the case.
Due to the improper interpretations and applications arrived at by the lower courts on this
particular issue, the SC found it wise to construe the law and lay down guidelines in interpretation and
application of Art. 36. Here, the SC sought the help of two amici curiae considered an external aid in
statutory construction. The guidelines set forth are thus: (1) the burden of proof belongs to the plaintiff;
(2) the root cause of psychological incapacity must be medically or clinically identified, alleged in the
complaint, sufficiently proven by expert, and clearly explained in the decision; (3) the incapacity must be
proven to be existing at the time of the celebration of marriage; (4) the incapacity must be medically or
clinically permanent or incurable; (5) such illness must be grave enough to disable fulfillment of essential
marital obligations; (6) the essential marital obligation must be embraced by Articles 68 to 71 of the
Family Code as regards husband and wife, and Articles 220 to 225 of the same code as regards parents
and their children; (7) interpretation made by the National Appellate Matrimonial Tribunal of the
Catholic Church are to be given great weight; and (8) the fiscal and the Solicitor-General must appear as
counsel for the State.