Professional Documents
Culture Documents
CA and Molina (MJ) his or her conduct in the long haul for the attainment of the principal objectives of
Syllabus Topic : Psychological incapacity under FC 36 marriage; where said conduct, observed and considered as a whole, tends to
cause the union to self-destruct because it defeats the very objectives of marriage,
FACTS : warrants the dissolution of the marriage.
This is a petition for review on certiorari by the Solicitor General assailing the
January 25, 1993 Decision of the Court of Appeals in CA-G. R. CV No. 34858 which The Court reiterated its ruling in Santos v. Court of Appeals, where psychological
affirmed the May 14, 1991 Decision of the Regional Trial Court of La Trinidad, incapacity should refer to no less than a mental (not physical) incapacity, existing
Benguet, declaring the respondent Roridel Olaviano Molina and Reynaldo Molina’s at the time the marriage is celebrated, and that there is hardly any doubt that the
marriage as void ab initio, on the ground of “psychological incapacity” under Article intendment of the law has been to confine the meaning of ‘psychological
36 of the Family Code. incapacity’ to the most serious cases of personality disorders clearly
demonstrative of an utter insensitivity or inability to give meaning and significance
Roridel Olaviano was married to Reynaldo Molina on 14 April 1985 in Manila, and to the marriage. Psychological incapacity must be characterized by gravity,
gave birth to a son a year after. Reynaldo showed signs of “immaturity and juridical antecedence, and incurability. In the present case, there is no clear
irresponsibility” on the early stages of the marriage, observed from his tendency to showing to us that the psychological defect spoken of is an incapacity; but
spend time with his friends and squandering his money with them, from his appears to be more of a “difficulty,” if not outright “refusal” or “neglect” in the
dependency from his parents, and his dishonesty on matters involving his performance of some marital obligations. Mere showing of “irreconcilable
finances. Reynaldo was relieved of his job in 1986, Roridel became the sole differences” and “conflicting personalities” in no wise constitutes psychological
breadwinner thereafter. In March 1987, Roridel resigned from her job in Manila and incapacity.
proceeded to Baguio City. Reynaldo left her and their child a week later. The couple
is separated-in-fact for more than three years. Morever, the evidence adduced by respondent merely showed that she and her
husband could nor get along with each other. In the case of Reynaldo, there is no
On 16 August 1990, Roridel filed a verified petition for declaration of nullity of her showing that his alleged personality traits were constitutive of psychological
marriage to Reynaldo Molina. Evidence for Roridel consisted of her own testimony, incapacity existing at the time of marriage celebration. While some effort was
that of two of her friends, a social worker, and a psychiatrist of the Baguio General made to prove that there was a failure to fulfill pre-nuptial impressions of
Hospital and Medical Center. Reynaldo did not present any evidence as he "thoughtfulness and gentleness" on Reynaldo's part of being "conservative, homely
appeared only during the pre-trial conference. On 14 May 1991, the trial court and intelligent" on the part of Roridel, such failure of expectation is nor indicative
rendered judgment declaring the marriage void. The Solicitor General appealed to of antecedent psychological incapacity. If at all, it merely shows love's temporary
the Court of Appeals. The Court of Appeals denied the appeals and affirmed in toto blindness to the faults and blemishes of the beloved.
the RTC’s decision. Hence, the present recourse.
The Supreme Court granted the petition, and reversed and set aside the assailed
ISSUE : Whether opposing or conflicting personalities should be construed as decision; concluding that the marriage of Roridel Olaviano to Reynaldo Molina
psychological incapacity subsists and remains valid.
HELD : The Court of Appeals erred in its opinion the Civil Code Revision Committee
intended to liberalize the application of Philippine civil laws on personal and family
rights, and holding psychological incapacity as a broad range of mental and
behavioral conduct on the part of one spouse indicative of how he or she regards
the marital union, his or her personal relationship with the other spouse, as well as
2