Republic vs.

CA and Molina
G.R. No. 108763
February 13, 1997

FACTS
This is a petition for review on certiorari challenging the
decision of Court of Appeals (CA) affirming the marriage of
respondent Roridel Molina to Reynaldo Molina void ab initio, on
the ground of "psychological incapacity".
The couple got married in 1985, after a year, Reynaldo
manifested signs of immaturity and irresponsibility both as
husband and a father preferring to spend more time with friends
whom he squandered his money, depends on his parents for
aid and assistance and was never honest with his wife in regard
to their finances. In 1986, the couple had an intense quarrel
and as a result their relationship was estranged. Roridel quit
her work and went to live with her parents in Baguio City in
1987 and a few weeks later, Reynaldo left her and their child.
Since then he abandoned them.
Roridel then filed a petition for declaration of nullity of marriage
before the RTC of La Trinidad on the grounds of psychological
incapacity which allege that Reynaldo was incapable of
complying with essential marital obligations and was a highly
immature; 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. The trial court declared the marriage void finding that "that
the marriage between the parties broke up because of their
opposing and conflicting personalities." Then, it added its own
opinion that "the Civil Code Revision Committee (hereinafter
referred to as Committee) intended to liberalize the application
of our civil laws on personal and family rights, which the CA
affirmed in toto; hence, the Solicitor General filed a petition for
certiorari.
ISSUE
Whether “opposing and conflicting personalities” is equivalent
to psychological incapacity and therefore void.

RULING
No. The marriage between Roridel and Reynaldo subsists and
remains valid. 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. In addition, the expert testimony by
Dr Sison showed no incurable psychiatric disorder but only
incompatibility which is not considered as psychological
incapacity.
The following are the guidelines as to the grounds of
psychological incapacity laid set forth in this case: (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.