REPUBLIC VS. MOLINA G.R. NO. 108763.

FEBRUARY 13, 1997

FACTS:

Roridel Molina and Reynaldo Molina were married on April 14, 1985. A son, Andre Molina was
born out of their marriage in 1986. However, a year after their marriage, Roridel alleged that her
husband Reynaldo showed signs of immaturity and irresponsibility as a husband and a father.
Reynaldo, as claimed was spending more time with his friends, depending on his parents for aid
and assistance, and was dishonest with his wife regarding their finances. He even lost his job
and abandon his family. Thus, due to his immaturity and actions that lead to their frequent
quarrels, their relationship was estranged and resulted to the filing of this case to declare the
marriage null and void on ground of psychological incapacity.

ISSUE:

Whether the marriage of Reynaldo and Roridel shall be declared null and void on ground of
psychological incapacity.

RULING:

No. The court ruled that psychological incapacity should refer to no less than a mental nor
physical incapacity. The law intended to confine the meaning of psychological incapacity to the
most serious cases of personality disorders clearly demonstrative of an utter insensitivity or
inability to give meaning and significance to the marriage. The condition must exist at the time
of the celebration of the marriage and must be characterized by (a) gravity, (b) juridical
antecedence, and (c) incurability.

In this case, there is no clear showing that the defect spoken of is an incapacity, but instead is
likely to appear as 'difficulty', if not outright 'refusal' or 'neglect' in the performance of some
marital obligations. Mere showing of "irreconcilable differences" and "conflicting personalities"
in no wise constitutes psychological incapacity. Their problem shows no gravity, neither
juridical antecedence nor its incurability.
This case introduced the following guidelines in the interpretation and application of Art. 36 of
the Family Code: (Molina Doctrine-as it is called today)

1. The burden of proof to show the nullity of the marriage belongs to the plaintiff. Any doubt
should be resolved in favor of the marriage and against its dissolution and nullity.

2. The root cause of the psychological incapacity must be:

a. Medically or clinically identified;

b. Alleged in the complaint;

c. Sufficiently proven by experts; and

d. Clearly explained in the decision.

3. The incapacity must be proven to be existing at the "time of the celebration" of the marriage.

4. The incapacity must also be shown to be medically or clinically incurable.

5. Such illness must be grave enough to bring about the disability of the party to assume the
essential obligations of marriage.

6. The essential marital obligations must be those embraced by Articles 68 to 71 of the Family
Code as well as Articles 220, 221 and 225 of the same Code.

7. Interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church
in the Philippines, while not controlling or decisive, should be given great respect by our Courts.

8. The trial court must order the prosecuting attorney or fiscal and the Solicitor General to
appear as counsel for the State.