REPUBLIC V.

MOLINA
FACTS
Roridel & Reynaldo Molina were married on April 14, 1985 at the San Agustin Church. They had a son, Andre Molina. A
year after the marriage, Reynaldo started manifesting signs of immaturity and irresponsibility: (1) spent more time with his
friends (2) depended on his parents for aid & assistance (3) not honest with the finances (4) relieved of his job making
Roridel the breadwinner of the family. Roridel went to live with his parents and afterwards, Reynaldo abandoned her and
the child. Roridel filed a case for the declaration of nullity of their marriage by virtue of her husbands psychological
incapacity. Reynaldo claims that Roridels strange behavior, refusal to perform marital duties & failure to run the household
& handle finances caused their quarrels. Roridel on the other hand claims that her husband is immature, irresponsible,
dependent, disrespectful, arrogant, chronic liar & infidel. He now lives with a mistress with whom he has a child.
ISSUE
WON Reynaldo is psychologically incapacitated?
HELD
NO. Marriage is valid.
RATIO:
1. They seem to have a difficulty or outright refusal or neglect in performing their obligations. Theyre not incapable of
doing them.
2. Failure of their expectations is not tantamount to psychological incapacity.
3. Guidelines for Art. 36
a. Burden of proof to show nullity of marriage: plaintiff. Presumption of existence of marriage over its dissolution & nullity.
b. Root cause of incapacity should be: medically/clinically defined, alleged in complaint, proven by experts, clearly
explained in decision.
c. Existing at time of celebration of marriage.
d. Medically/clinically permanent or incurable, whether absolute or relative. Incapacity directly related to assumption of
marital obligations, doesnt include incapacity in profession, etc.
e. Grave to render them incapable. Not mere refusal, neglect or difficulty or ill will.
f. Essential obligations outlined in FC Art. 68-71 and 220, 221, 225. State non-compliance in petition with evidence,
include in decision.
g. Consider National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines interpretations. Not binding
should be given respect since this law originated from Canon law. Harmonize civil law w/religious faith.
h. Prosecuting attorney/fiscal and Sol. Gen. will appear as counsels for the state. They should submit certification within
15 days from submission of case for resolution.
FACTS:
Roridel and Reynaldo got married in 1985 in Manila. During the early years of their marriage, Reynaldo showed signs of
immaturity and irresponsibility, observed from his tendency to spend time with his friends and squandered money with
them, his dependency from his parents for financial aid and dishonesty in matters involving finances. Roridel became the
sole breadwinner of the family. She then resigned her job in Manila and went to Baguio. Reynaldo left her and their child a
week later. The couple is separated in fact for more than 3 years.
Roridel filed a petition to have their marriage void under Article 36, citing Reynaldo's psychological incapacity. She
presented evidence consisted of her own testimony, of her two friends, a social worker and a psychiatrist. Reynaldo did
not present any evidence and appeared only during the pre-trial. The RTC granted the petition, declaring the marriage
void. Solicitor General appealed to the CA. CA denied the appeals and ruled in favor of the trial court.
ISSUE:
Whether or not opposing or conflicting personalities constitute psychological incapacity.
RULING:
No. There is no clear showing to us that the psychological defect spoken of is an incapacity; but appears to be more of a
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.
The Court, in this case, promulgated guidelines in the interpretation and application of Article 36 of the Family Code: 1)
The burden of proof to show the nullity of marriage belongs to the plaintiff; 2) the root cause of PI must be (a) medically or
clinically identified (b) alleged in the complaint (c) sufficiently proven by experts (d) clearly explained in the decision; 3) it
must be existing at the time of the celebration of the marriage; 4) it must be medically or clinically permanent or incurable;
5) it must be grave enough to bring about the disability of the party to assume the marital obligations of marriage; 6) the
marital obligations must be embraced by Articles 68 to 71, and Articles 220, 221 and 225 in regard of parents and their
children; 7) interpretation by the National Appellate Matrimonial Tribunal of Catholic of Church of the Philippines, although
not binding, should be given great respect; and 8) the prosecuting attorney or fiscal and the Solicitor General must appear
as counsel for the State.