Title
Aurelio vs. Aurelio
Case
G.R. No. 175367
Decision Date
Jun 6, 2011
A couple sought marriage nullity citing psychological incapacity under Article 36. Courts upheld the petition's sufficiency, affirming compliance with Molina guidelines and denying dismissal.
nullity of marriage
psychological incapacity
declaration of nullity

Case Summary (G.R. No. 175367)

Factual Background

Respondent’s petition alleged that both parties were psychologically incapacitated to perform and comply with essential marital obligations. The alleged juridical antecedence was that the psychological incapacity was already present before and during the marriage ceremony. Respondent attributed her alleged incapacity to a psychological profile described as histrionic personality disorder with narcissistic features, while petitioner was described as suffering from passive aggressive (negativistic) personality disorder. Respondent further alleged manifestations of the purported incapacity in the parties’ conduct toward each other and toward family life, including lack of financial support by petitioner, difficulty in discerning the plight of the working wife, persistent jealousy and distrust, alternating hostility and contrition, refusal to assist in family maintenance, refusal to pay household bills, arrogance, insensitivity to the wife’s feelings, and humiliation of respondent even in the presence of their children. Respondent’s alleged symptoms included frequent and rapid emotional shifts, low tolerance for boredom, emotional immaturity, inability to tolerate frustration or disappointment, inability to delay gratification, and anger when she did not get what she wanted. Respondent also alleged that the hostile relationship and these behavioral patterns led to the breakdown of the marriage. A psychologist was said to have clinically found the incapacity of both spouses to be grave, incorrigible, and incurable.

RTC Proceedings and the Motion to Dismiss

After respondent filed the petition on May 9, 2002, petitioner filed a Motion to Dismiss on November 8, 2002. Petitioner argued that the petition failed to state a cause of action and failed to meet the standards set by the Court for interpreting and applying Article 36—particularly the requirements derived from the Molina doctrine. The RTC denied the motion on January 14, 2003. Petitioner sought reconsideration, but the RTC denied it on December 17, 2003. In its denial, the RTC ruled that respondent’s petition complied with the Molina requirements. It concluded that the petition contained allegations on the root cause of the psychological incapacity, the juridical antecedence, the gravity and incurability of the condition, and quotations regarding incurability attributed to the clinical finding of a psychologist. The RTC emphasized that whether the allegations were meritorious would depend on the evidence to be presented during trial.

Appellate Review in the CA

Instead of proceeding directly through an ordinary appeal, petitioner filed in the CA a petition for certiorari under Rule 65 on February 16, 2004, assailing the RTC’s denial of the motion to dismiss. On October 6, 2005, the CA dismissed the petition. In the October 26, 2006 Resolution, the CA likewise dismissed petitioner’s motion for reconsideration. The CA affirmed the RTC and held that the complaint for declaration of nullity of marriage, when assessed alongside Article 36 and the Molina doctrine, alleged a sufficient cause of action.

The Issues Raised Before the Supreme Court

Petitioner then elevated the matter to the Supreme Court. He raised two issues. First, he argued that the CA violated applicable law and jurisprudence when it held that the allegations in respondent’s petition were sufficient for a declaration of nullity. Second, he contended that the CA erred in dismissing his petition for certiorari despite an alleged grave abuse of discretion by the RTC in denying his motion to dismiss, and despite his claim that appeal would not be a plain, adequate, or speedy remedy under the circumstances.

Supreme Court’s Discussion of the Molina Guidelines

The Court proceeded to examine the contention that respondent’s petition did not satisfy the Molina guidelines. The Court recalled that Republic v. Court of Appeals laid down guidelines for cases involving psychological incapacity under Article 36: the plaintiff bears the burden of proof; the root cause must be medically or clinically identified, alleged in the complaint, sufficiently proven by experts, and clearly explained in the decision; the incapacity must exist at “the time of the celebration” of the marriage; the condition must be medically or clinically permanent or incurable; it must be grave enough to prevent a party from assuming essential marital obligations; the essential obligations must be those found in Articles 68 to 71 (as to husband and wife) and Articles 220, 221, and 225 (as to parents and children) of the Family Code; interpretations by the National Appellate Matrimonial Tribunal of the Catholic Church should be given great respect; and the trial court must order the prosecuting attorney and the Solicitor General to appear, with certification by the Solicitor General. The Court noted that the Solicitor General certification requirement in Molina was later dispensed with to avoid delay, pursuant to Supreme Court Administrative Matter No. 02-11-10, while retaining the mandate under Article 48 of the Family Code that the prosecuting attorney or fiscal appear for the State to prevent collusion and to ensure evidence is not fabricated or suppressed.

Whether the Petition Alleged the Root Cause, Gravity, and the Non-Complied Marital Obligations

Petitioner focused on three asserted deficiencies: that respondent’s complaint allegedly failed to (a) allege the root cause of psychological incapacity, (b) state that the illness was grave enough to disable the party to assume essential obligations, and (c) identify the non-complied essential marital obligations. The Court rejected these arguments.

First, the Court held that contrary to petitioner’s claim, the root cause was stated and alleged in the complaint. It agreed that the family backgrounds of both spouses were discussed in the petition as the root causes of their psychological incapacity, and that an expert psychologist had clinically identified those as root causes.

Second, the Court held that the petition also alleged the incapacity to be grave in nature. It cited the allegations that respondent suffered from Histrionic Personality Disorder with Narcissistic Features, and that petitioner suffered from Passive Aggressive (Negativistic) Personality Disorder, with the incapacity of both parties alleged to be grave, incorrigible, and incurable.

Third, the Court held that respondent’s petition alleged the essential marital obligations that were allegedly not complied with. It treated respondent’s allegations as falling within Article 68 of the Family Code, which obliges spouses to live together, observe mutual love, respect and fidelity, and render mutual help and support.

Timing of Adjudication and the RTC’s Role

The Court stressed that whether the parties were psychologically incapacitated was, in the ordinary course of such litigation, a matter to be determined by the RTC in the first instance after trial and evaluation of evidence. It observed that the Molina guidelines contemplate assessment after evidence is presented, witnesses testify, and the court reaches findings in a decision following due hearing, as reflected in the guidelines relating to trial and decision-making. The Court found it burdensome to require it to resolve at first instance whether the allegations were sufficient to warrant a declaration, since each Article 36 case must be judged on its own attendant facts and not by prior assumptions or generalizations. It emphasized that courts should interpret Article 36 case-to-case, guided by experience, expert findings in psychology, and decisions of church tribunals.

In light of this approach, the Court considered it prudent not to substitute its evaluation for that of the RTC. Th

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