Case Summary (G.R. No. 108763)
Facts of the Case
Roridel Molina petitioned to declare her marriage void ab initio for Reynaldo’s alleged psychological incapacity: immaturity, irresponsibility, financial dependence, chronic lying, infidelity, habitual quarrels, and abandonment since early 1987. Reynaldo admitted separation but blamed incompatibility on his wife’s insistence on maintaining friendships, neglect of household duties, and mismanagement of finances. The parties stipulated to their valid marriage, the birth of their child, over three years of de facto separation, no support or damages claims, and child custody in wife’s favor. Evidence consisted of testimony from respondent, friends, a social worker, and a psychiatrist; no evidence was offered by the husband. The RTC declared the marriage void; the CA affirmed.
Issue Presented
Does mere “opposing and conflicting personalities” or failure to perform marital duties equate to “psychological incapacity” under Article 36 of the Family Code, thereby rendering the marriage void ab initio?
Applicable Law
1987 Constitution, Article XV (Family)—recognizes marriage as inviolable and to be protected by the State.
Family Code, Article 36—voids a marriage if, at solemnization, a party was psychologically incapacitated to comply with essential marital obligations, even if manifest only after solemnization.
Essential Marital Obligations: Arts. 68–71 (spousal obligations) and Arts. 220, 221, 225 (parental obligations).
Supreme Court’s Analysis
Referencing Santos v. Court of Appeals, the Court held that psychological incapacity is a serious mental (not physical) disorder demonstrative of utter inability to give meaning to marriage. It must exist at celebration of the marriage, be grave, antecedent, and incurable. The CA’s finding of conflicting personalities and irreconcilable differences was insufficient—mere neglect, refusal, or difficulty in fulfilling duties does not establish incapacity. Expert testimony in this case only proved incompatibility, not a permanent, clinically identifiable psychological defect present at the time of solemnization.
Guidelines for Interpreting Article 36
- Burden of proof on petitioner; doubts favor the continuity of marriage.
- Identify the root psychological illness: alleged in the complaint, clinically defined, proven by qualified experts, and explained in the decision.
- Incapacity must exist at the time of marriage celebration.
- Must be medically or clinically permanent or incurabl
Case Syllabus (G.R. No. 108763)
Facts
- 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 (psychological incapacity).
- The spouses were married on April 14, 1985 at San Agustin Church in Manila and had one son, Albert Andre Olaviano Molina, born July 29, 1986.
- Petitioner alleged that after one year of marriage, Reynaldo displayed immaturity and irresponsibility, neglected marital obligations, depended on his parents for support, and was dishonest about their finances, leading to frequent quarrels.
- In February 1986 Reynaldo lost his job; Roridel became sole breadwinner. By October 1986 their relationship had estranged after an intense quarrel.
- In March 1987 Roridel moved to Baguio City with her parents; Reynaldo abandoned his wife and child soon after.
- Roridel claimed Reynaldo’s conduct showed psychological incapacity to comply with essential marital obligations and sought nullity to free them from an incompatible union.
- In his August 28, 1989 Answer, Reynaldo admitted separation but attributed conflicts to Roridel’s insistence on maintaining premarital friendships, refusal to perform household duties, and failure to manage finances.
- During pre-trial, the parties stipulated to their valid marriage, the birth and custody of their child, over three years of separation-in-fact, and that neither party sought support or damages.
- Roridel presented testimony from herself, friends, a social worker, and Dr. Teresita Hidalgo-Sison (psychiatrist). Reynaldo offered no evidence beyond his Answer.
- On May 14, 1991, the RTC of La Trinidad, Benguet declared the marriage void ab initio for psychological incapacity.
- The Court of Appeals affirmed the RTC decision on January 25, 1993. The Solicitor General then filed a petition for certiorari under Rule 45 before the Supreme Court.
Issue
- Whether the Court of Appeals erred in interpreting and applying “psychological incapacity” under Article 36 of the Family Code.
- Whether the CA’s expansive reading of Article 36 effectively created the