Case Summary (G.R. No. 175367)
Facts of the Case
The respondent filed the petition on May 9, 2002, in the Regional Trial Court (RTC) of Quezon City, Branch 94, asserting that both parties were psychologically incapacitated to fulfill essential marital obligations, thus rendering their marriage void under Article 36 of the Family Code. The petition detailed various manifestations of psychological incapacity, including the husband's lack of financial support, jealousy, and emotional behavior, alongside the respondent's own issues including immaturity and emotional volatility. The psychological assessment indicated that the petitioner suffered from a passive-aggressive personality disorder, while the respondent was diagnosed with a histrionic personality disorder.
Initial Proceedings
The petitioner initially responded by filing a Motion to Dismiss on November 8, 2002, arguing that the petition lacked a cause of action and failed to meet the standards set forth by the jurisprudence concerning Article 36. On January 14, 2003, the RTC denied the motion, with subsequent motions for reconsideration also denied. The RTC concluded that the petition met the standards established by the Molina Doctrine, which provided the criteria for determining psychological incapacity.
Court of Appeals' Decision
On February 16, 2004, the petitioner escalated his challenge to the Court of Appeals (CA) through a petition for certiorari. Ultimately, on October 6, 2005, the CA upheld the RTC's decision, affirming that sufficient cause for the nullity of marriage existed per Article 36, thus confirming the initial findings regarding psychological incapacity.
Grounds for Petitioner's Argument
In the Supreme Court, the petitioner raised two main issues: whether the CA violated applicable law by affirming the sufficiency of the respondent’s allegations for nullity of marriage and whether the CA abused its discretion by dismissing the certiorari action concerning the RTC’s denial of the motion to dismiss.
Examination of Arguments
The Supreme Court underscored that had the respondent's complaint been filed post-March 15, 2003, the motion to dismiss would not have been permissible, per a preceding administrative ruling. Referring to the Molina guidelines, the Court confirmed that the burden of proof lies with the complainant to establish the psychological incapacity.
Despite the petitioner's claims, the Court determined that the root causes of psychological incapacity were indeed indicated in the allegations, as was the requisite severity and irreparability of the disorders affecting both parties. It further noted that the essential obligations outlined in the Family Code wer
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Case Overview
- This case involves a petition for review on certiorari filed by Danilo A. Aurelio against Vida Ma. Corazon P. Aurelio regarding the declaration of nullity of their marriage.
- The petition seeks to set aside the October 6, 2005 Decision and October 26, 2006 Resolution of the Court of Appeals (CA), which dismissed the petitioner's appeal.
- The case is grounded in claims of psychological incapacity under Article 36 of the Family Code.
Background of the Parties
- Petitioner, Danilo A. Aurelio, and respondent, Vida Ma. Corazon P. Aurelio, were married on March 23, 1988, and have two sons: Danilo Miguel and Danilo Gabriel.
- Respondent filed a Petition for Declaration of Nullity of Marriage on May 9, 2002, alleging psychological incapacity affecting both parties.
Allegations of Psychological Incapacity
- Respondent claimed both parties were psychologically incapacitated to fulfill essential marital obligations before and during the marriage.
- The petition highlighted several manifestations of this incapacity:
- Petitioner displayed consistent jealousy, distrust, and lack of financial support.
- He exhibited hostile defiance, mood swings, and arrogance, showing insensitivity towards respondent.
- Respondent was described as emotionally immature and self-indulgent, with rapid mood changes and intolerance for disappointment.
- A psychologist evaluated both parties, diagnosing respon