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REPUBLIC v. RORIDEL OLAVIANO MOLINA

FACTS:

Roridel O. Molina filed a petition for declaration of nullity of marriage against her husband Reynaldo Molina. Roridel claimed that after a year of marriage, Reynaldo exhibited immaturity and irresponsibility by prioritizing his peers and friends over their relationship, mismanaging their finances, and being dishonest about their financial situation. Consequently, Roridel became the sole breadwinner, leading to estrangement between them. Reynaldo eventually abandoned Roridel and their child. Roridel argued that Reynaldo's behavior indicated psychological incapacity and sought the nullification of their marriage. In his answer, Reynaldo placed the blame for their misunderstandings and frequent quarrels on Roridel's behavior and refusal to fulfill her marital obligations. During pre-trial, both parties agreed to certain stipulations, and evidence was presented during the trial. The trial court declared the marriage null and void, a decision that the Court of Appeals affirmed. The Solicitor General appealed, positing that the Court of Appeals' interpretation of psychological incapacity resulted in a liberal divorce procedure, which he contended to be incorrect.

ISSUES:

  1. Whether the respondent's behavior constitutes psychological incapacity as defined under Article 36 of the Family Code.

  2. Whether the evidence presented by the respondent sufficiently proves the existence of psychological incapacity.

  3. Whether or not the illness of one party must be existing at the time of marriage in order to be a ground for declaring the marriage void under Article 36 of the Family Code.

  4. Whether or not the illness must be medically or clinically permanent or incurable.

  5. Whether or not the illness must be relevant to the assumption of marriage obligations.

  6. Whether or not the illness must be grave enough to bring about the disability of the party to assume the essential obligations of marriage.

  7. Whether or not the essential marital obligations must be specifically stated in the petition and proven by evidence.

  8. Whether or not decisions of the National Appellate Matrimonial Tribunal of the Catholic Church should be given persuasive effect in interpreting Article 36 of the Family Code.

  9. Whether or not the Solicitor General must issue a certification in cases involving the declaration of nullity of marriage under Article 36.

RULING:

  1. The Court ruled that the respondent's behavior does not constitute psychological incapacity as defined under Article 36 of the Family Code. Mere showing of "irreconciliable differences" and "conflicting personalities" is not enough to prove psychological incapacity. It is essential to show that the parties are incapable of fulfilling their responsibilities and duties as married persons due to some psychological illness.

  2. The evidence presented by the respondent, which showed incompatibility and failure to fulfill pre-nuptial impressions, does not sufficiently prove the existence of psychological incapacity. The expert testimony presented by the respondent's witness only showed incompatibility, not psychological incapacity.

  3. The Supreme Court granted the petition, reversed and set aside the assailed decision, and declared that the marriage of the parties subsisted and remained valid.

PRINCIPLES:

  • The burden of proof to show the nullity of the marriage belongs to the plaintiff. Any doubt should be resolved in favor of the existence and continuation of the marriage and against its dissolution and nullity.

  • The root cause of the psychological incapacity must be medically or clinically identified, alleged in the complaint, sufficiently proven by experts, and clearly explained in the decision.

  • The incapacity must be proven to be existing at the time of the celebration of the marriage.

  • The illness must be existing at the time of marriage, but its manifestation need not be perceivable at such time. The illness itself must have attached at such moment, or prior thereto.

  • The incapacity must be medically or clinically permanent or incurable, either absolutely or relative to the other spouse.

  • The illness must be relevant to the assumption of marriage obligations and must be grave enough to bring about the disability of the party to assume such obligations.

  • The essential marital obligations must be those embraced by the Family Code, specifically Articles 68 to 71, and 220, 221, and 225.

  • Interpretations of the National Appellate Matrimonial Tribunal of the Catholic Church, while not controlling or decisive, should be given great respect by courts since Article 36 of the Family Code is meant to harmonize civil laws with the religious faith of the people.

  • The Solicitor General must issue a certification briefly stating his reasons for agreement or opposition to the petition, and such certification is necessary before a decision can be handed down. The Solicitor General performs the function of the defensor vinculi as contemplated under Canon 1095.