Facts:

In the case of Danilo A. Aurelio vs. Vida Ma. Corazon P. Aurelio, registered as G.R. No. 175367, the parties are Danilo A. Aurelio (the petitioner) and Vida Ma. Corazon P. Aurelio (the respondent). They were married on March 23, 1988, and have two sons, Danilo Miguel and Danilo Gabriel. On May 9, 2002, Vida Aurelio filed a Petition for Declaration of Nullity of Marriage with the Regional Trial Court (RTC) of Quezon City, Branch 94. The core of her petition was that both she and Danilo were psychologically incapacitated to fulfill their essential matrimonial duties, which she claimed existed prior to and during the marriage. Vida articulated allegations of Danilo’s psychological incapacity including lack of financial support, extreme jealousy, emotional defiance, and insensitivity. Danilo was characterized as exhibiting hostile behavior and neglecting his responsibilities, and his actions were alleged to have caused considerable discord in their relationship. Vida herself was fou

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Facts:

Marriage and Parties

• Petitioner Danilo A. Aurelio and respondent Vida Ma. Corazon P. Aurelio were married on March 23, 1988.
• The couple has two sons, namely Danilo Miguel and Danilo Gabriel.

Petition for Declaration of Nullity

• On May 9, 2002, respondent filed a Petition for Declaration of Nullity of Marriage before the Regional Trial Court (RTC) of Quezon City, Branch 94.
• The petitioner/respondent alleged that both parties were psychologically incapacitated to perform the essential marital obligations, and that this incapacity existed prior to and during the marriage ceremony.
• The petition invoked Article 36 of the Family Code, which declares a marriage void if contracted by a party psychologically incapacitated to comply with its essential obligations.

Allegations of Psychological Incapacity

• The petition alleged that both husband and wife were psychologically unable to perform their marital duties.
• Specific details included:
• Petitioner’s lack of financial support, absence of drive, and inability to discern the respondent’s plight.
• Display of jealousy, alternating moods of hostility and contrition, and refusal to provide for family needs exhibited by the petitioner.
• Respondent’s emotional volatility, low tolerance for boredom, rapid mood swings ranging from joy to fury, and inability to delay gratification.
• The existence of a distorted marital relationship with hostility and psychological aversion toward cohabitation.
• A competent psychologist evaluated both parties, diagnosing:
• Respondent with Histrionic Personality Disorder with Narcissistic features.
• Petitioner with Passive Aggressive (Negativistic) Personality Disorder.
• The psychological incapacity was described as grave, incorrigible, and incurable.

Proceedings in the Regional Trial Court

• On November 8, 2002, petitioner filed a Motion to Dismiss the petition, arguing that:
• The complaint failed to state a cause of action.
• It did not meet the necessary standards prescribed by the Court for the implementation of Article 36.
• On January 14, 2003, the RTC issued an Order denying petitioner’s motion to dismiss.
• On February 21, 2003, petitioner filed a Motion for Reconsideration, which was denied on December 17, 2003.
• The RTC relied on the Molina doctrine, noting:
• The complaint stated the root cause of psychological incapacity, including family background details.
• The allegations regarding the manifestation, gravity, and incurability of the incapacity were sufficiently detailed.
• The presence of a cause of action existed, contingent upon the presentation of proof during trial.

Appeal to the Court of Appeals

• Petitioner appealed the RTC’s decision on February 16, 2004, via a petition for certiorari under Rule 65 of the Rules of Court.
• On October 6, 2005, the Court of Appeals (CA) rendered a Decision dismissing the petition outright.
• Additionally, on October 26, 2006, the CA dismissed petitioner’s motion for reconsideration.
• The CA affirmed that the respondent’s petition, when evaluated under Article 36 and the Molina doctrine, presented a sufficient cause of action for nullity.

Issues Raised by the Petitioner

• Petitioner contended that the allegations in the nullity petition were insufficient under Article 36 because:
• The root cause of the psychological incapacity was not adequately alleged.
• The illness was not demonstrated to be grave enough to disable the party from fulfilling marital obligations.
• The non-complied marital obligations were not clearly stated.
• He further argued that the RTC’s denial of his motion to dismiss was tainted with grave abuse of discretion, and that the remedy of appeal was not adequate under the circumstances.

Issue:

Whether the Court of Appeals erred in holding that the allegations in the petition for declaration of nullity of marriage were sufficient to declare the marriage null.

• Specifically, whether the complaint met the requirements established under the Molina guidelines, including proper allegation of the root cause, gravity of the incapacity, and the non-fulfillment of essential marital obligations.

Whether the CA committed a grave abuse of discretion by denying petitioner’s action for certiorari on the ground that the denial of his motion to dismiss by the RTC was not indicative of lack or excess of jurisdiction.

• Petitioner argued that the denial of his motion was arbitrarily decided, constituting a reversible error not subject to appeal but remedied by certiorari.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)