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Republic vs Molina

The case at bar involves a petition for review on Certiorari challenging the
decision of the Court of Appeals (CA) declaring the marriage of respondent Roridel
Olaviano Molina to Reynaldo Molina void ab initio on the ground of “psychological
incapacity” under Article 36 of the Family Code.
The Supreme Court speaking through Mr. Justice Artemio V. Panganiban
granted the petition and reversed the CA decision by ruling that the marriage of the
spouses subsists and remains valid.
The arguments below support the finding of the Court that the requisites of
psychological incapacity have not been complied with in this case. Thus, the
marriage of the Molina spouses does not qualify for declaration of nullity.
The records of the case show that the spouses married sometime in April
1985. It was a year after said union that conflicts had arisen thereby turning the
relationship sour. The facts, as alleged, stated:
That after a year of marriage, Reynaldo showed signs of
"immaturity and irresponsibility" as a husband and a father
since he preferred to spend more time with his peers and
friends on whom he squandered his money; that he depended
on his parents for aid and assistance, and was never honest
with his wife in regard to their finances, resulting in frequent
quarrels between them; that sometime in February 1986,
Reynaldo was relieved of his job in Manila, and since then
Roridel had been the sole breadwinner of the family; that in
October 1986 the couple had a very intense quarrel, as a result
of which their relationship was estranged; that in March 1987,
Roridel resigned from her job in Manila and went to live with
her parents in Baguio City; that a few weeks later, Reynaldo
left Roridel and their child, and had since then abandoned
them; that Reynaldo had thus shown that he was
psychologically incapable of complying with essential marital
obligations and was a highly immature and habitually quarrel
some individual who thought of himself as a king to be served;
and that it would be to the couple's best interest to have their
marriage declared null and void in order to free them from
what appeared to be an incompatible marriage from the start. 1
In one decision of the Supreme Court penned by Mr. Justice Jose C. Vitug, it has
been laid out that the psychological incapacity must be characterized by (a) gravity,
1 Republic of the Philippines vs. Court of Appeals, G.R. No. 108763, (insert SCRA
number), (insert page number)

2 Republic of the Philippines vs. 36 of the Family Code as furnished by the Supreme Court to aid the bench and the bar. (insert SCRA number). The Court resolved to grant the petition and set aside the CA pronouncement. There had been no showing of the gravity of the problem. and (c) incurability. these attributes were not proven in this case: On the other hand. 108763. it is essential that they must be shown to be incapable of doing so. neither its juridical antecedence nor its incurability. 2 In addition to the arguments disproving the presence of psychological incapacity.R. Court of Appeals. applying the guidelines in the interpretation and application of Art. there is no clear showing to us that the psychological defect spoken of is an incapacity. No. If at all. Court of Appeals. the Court added that there was no showing that Reynaldo’s alleged personality traits constituting incapacity has been existing at the time of marriage celebration: While some effort was made to prove that there was a failure to fulfill pre-nuptial impressions of "thoughtfulness and gentleness" on Reynaldo's part of being "conservative.(b) juridical antecedence. (insert SCRA number). G. such failure of expectation is not indicative of antecedent psychological incapacity. It appears to us to be more of a "difficulty. (insert page number) 3 Republic of the Philippines vs.R. (insert page number) . No. in the present case. it merely shows love's temporary blindness to the faults and blemishes of the beloved." if not outright "refusal" or "neglect" in the performance of some marital obligations. It is not enough to prove that the parties failed to meet their responsibilities and duties as married persons. homely and intelligent" on the part of Roridel. the present case failed to qualify as one covered by the psychological incapacity provision. However. The evidence adduced by respondent merely showed that she and her husband could nor get along with each other. due to some psychological (nor physical) illness. Mere showing of "irreconcilable differences" and "conflicting personalities" in no wise constitutes psychological incapacity. 108763. 3 Thus. G.