Case Digest (G.R. No. 108763)
Facts:
In Republic of the Philippines v. Court of Appeals and Roridel Olaviano Molina (G.R. No. 108763, February 13, 1997), respondent Roridel Molina filed on August 16, 1990 a verified petition before the Regional Trial Court (RTC) of La Trinidad, Benguet seeking a declaration that her marriage to Reynaldo Molina, solemnized on April 14, 1985 at San Agustin Church in Manila, was void ab initio for psychological incapacity under Article 36 of the Family Code. The petition recounted that the couple had one child, Andre (born July 29, 1986), and that after one year of marriage Reynaldo displayed immaturity, irresponsibility, habitual quarrelsomeness and abandonment, relying on his parents for support, deceiving Roridel about their finances, losing his job, and eventually deserting his wife and child in March 1987. Reynaldo, in his August 28, 1990 answer, conceded separation but attributed quarrels to Roridel’s alleged neglect of household duties. During the RTC pretrial of October 17, 19Case Digest (G.R. No. 108763)
Facts:
- Background and Petition
- On August 16, 1990, respondent Roridel O. Molina filed a verified petition for declaration of nullity of her marriage to Reynaldo Molina under Article 36 of the Family Code, alleging “psychological incapacity.”
- The parties were married on April 14, 1985 at San Agustin Church in Manila and had one son, Albert Andre Olaviano Molina, born July 29, 1986.
- Allegations and Evidence
- Petition alleged that within a year the husband displayed immaturity, irresponsibility, quarrelsomeness, chronic lying and financial dependence on his parents, culminating in his abandonment of his wife and child in early 1987.
- Stipulated matters at pre-trial (October 17, 1990):
- Legal marriage date and child’s birthdate;
- Separation-in-fact for more than three years;
- No claim for support or damages;
- Custody of the child with the wife.
- Wife’s evidence: her testimony; testimonies of two friends, a social worker, and a psychiatrist; documentary exhibits. Husband presented no evidence, appearing only at pre-trial.
- Lower Court Decisions
- On May 14, 1991, the Regional Trial Court of La Trinidad, Benguet declared the marriage void ab initio for psychological incapacity.
- On January 25, 1993, the Court of Appeals affirmed the RTC decision, holding that opposing and conflicting personalities indicated psychological incapacity and liberalized the ground for annulment.
Issues:
- Interpretation of Psychological Incapacity
- Whether “psychological incapacity” under Article 36 requires a serious clinical personality disorder, or whether mere conflicting personalities and marital difficulties suffice.
- Application to Facts
- Whether the findings of immaturity, irresponsibility and abandonment by the husband met the requisites of gravity, juridical antecedence and incurability required for psychological incapacity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)