Case Digest (G.R. No. 108763)
Facts:
Republic of the Philippines v. Court of Appeals and Roridel Olaviano Molina, G.R. No. 108763, February 13, 1997, Supreme Court En Banc, Panganiban, J., writing for the Court.This case arose from a verified petition filed on August 16, 1990 by Roridel O. Molina seeking a declaration that her marriage to Reynaldo Molina (married April 14, 1985 at St. Augustine Church) was void ab initio for psychological incapacity under Article 36 of the Family Code. The petition alleged Reynaldo’s immaturity, irresponsibility, dependence on his parents, dishonesty about finances, infidelity and eventual abandonment of Roridel and their son. Reynaldo’s Answer (dated in the record August 28, 1989) admitted that they could no longer live together but attributed marital breakdown to Roridel’s conduct, refusing some marital duties and keeping friendships.
At pre-trial on October 17, 1990 the parties stipulated to marriage, paternity of a child, separation in fact for more than three years, that Roridel was not asking for support or damages, and custody of the common child remained with Roridel. Roridel presented her own testimony, testimony of friends, a social worker, and Dr. Teresita Hidalgo‑Sison (psychiatrist), plus documentary exhibits; Reynaldo presented no evidence and appeared only at pre-trial.
On May 14, 1991 the Regional Trial Court of La Trinidad, Benguet (presided by Judge Heilia S. Mallare‑Phillipps) declared the marriage void for psychological incapacity. The Court of Appeals (Sixteenth Division) affirmed in a January 25, 1993 decision (CA‑G.R. CV No. 34858), relying substantially on the RTC’s findings that opposing and conflicting personalities caused the marriage to break up and treating Article 36 expansively. The Solicitor General (on behalf of the Republic) filed a petition for review on certiorari under Rule 45 in the Supreme Court, contending the CA misinterpreted Article 36 and effectively created an overly liberal divorce procedure.
During Supreme Court deliberations the Court invited two amici curiae — Most Rev. Oscar V. Cruz (National Appellate Matrimonial Tribunal) and Justice...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in its interpretation of the phrase “psychological incapacity” under Article 36 of the Family Code?
- Did the evidence in this case establish psychological incapacity sufficient to render the marriage of Roridel and Reynaldo void ab initi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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