FACTS:

This case involves a marriage annulment on the ground of psychological incapacity. The petitioner, Jose Reynaldo Ochosa, filed a petition for declaration of nullity of his marriage with Bona Alano based on Bona's alleged psychological incapacity. Throughout their marriage, Jose was often assigned to different parts of the country for his job, and Bona preferred to stay in her hometown and did not cohabit with Jose in his posts. In 1987, Jose drove Bona away from their living quarters after Bona admitted to having a relationship with Jose's driver. Bona left with their daughter and returned to her hometown. In 1994, their daughter decided to leave Bona and live with Jose. In 1997, Jose filed a petition for the declaration of nullity of their marriage, citing Bona's psychological incapacity to fulfill the essential obligations of marriage. Bona was served with the petition but failed to file a responsive pleading. During trial, Jose presented witnesses, including a psychiatrist who diagnosed Bona with histrionic personality disorder. The Office of the Solicitor General opposed the petition, arguing that the facts did not support a declaration of nullity. The trial court granted the petition, but the Court of Appeals reversed the decision. Jose filed a petition with the Supreme Court.

ISSUES:

1. Whether or not the guidelines set in Molina v. Reyes are still applicable in determining psychological incapacity in marriage cases.

2. Whether or not an actual medical examination is required to establish psychological incapacity.

3. Whether Bona's alleged psychological incapacity satisfied the requirement of "juridical antecedence" under Article 36 of the Family Code.

4. Whether the evidence presented, specifically Dr. Rondain's testimony and psychiatric evaluation report, sufficiently establish Bona's psychological incapacity.

5. Whether a personal examination of the party alleged to be psychologically incapacitated is mandatory in cases of annulment based on psychological incapacity.

6. Whether conclusions and generalizations on a spouse's psychological condition can be made based solely on information fed by one party in the absence of personal knowledge.

7. Whether the wife's alleged psychological incapacity existed prior to the marriage.

8. Whether the husband's evidence sufficiently proved the wife's psychological incapacity.

9. Whether the wife's behavior constituted psychological incapacity under Article 36 of the Family Code.

RULING:

1. The guidelines set in Molina v. Reyes are still applicable in determining psychological incapacity in marriage cases. However, it is acknowledged that these guidelines may be inappropriate in resolving all cases of psychological incapacity, as it may not adequately address certain situations.

2. An actual medical examination is not required to establish psychological incapacity. What is crucial is the presence of evidence that can sufficiently establish the party's psychological condition.

3. Bona's alleged psychological incapacity did not satisfy the requirement of "juridical antecedence." There was inadequate credible evidence that her "defects" were already present at the inception of, or prior to, the marriage.

4. The evidence presented, specifically Dr. Rondain's testimony and psychiatric evaluation report, did not sufficiently establish Bona's psychological incapacity. The psychiatrist's findings were solely based on interviews with Jose and his witnesses, without a personal interview with Bona herself. This raises doubts on the credibility and impartiality of the information provided.

5. A personal examination of the party alleged to be psychologically incapacitated is not mandatory in cases of annulment based on psychological incapacity. While desirable, it may not be practical in all instances, especially when there are estranged relations between the parties. Information coming from persons with personal knowledge of the juridical antecedents may be helpful in determining a party's complete personality profile. This approach allows flexibility while avoiding credibility gaps from expert opinions based on doubtful sources of information.

6. Conclusions and generalizations on a spouse's psychological condition cannot be made based solely on information fed by one party. This is not different from admitting hearsay evidence as proof of the truthfulness of the content of such evidence.

7. The Court held that the wife's alleged psychological incapacity did not exist prior to the marriage. The evidence presented showed that the wife had no manifest desire to abandon the husband at the beginning of their marriage and was living with him for a substantial period of their relationship. The badges of the wife's alleged psychological incapacity, such as sexual infidelity and abandonment, could only be convincingly traced to the period of time after the marriage.

8. The Court also emphasized that Article 36 of the Family Code should not be confused with a divorce law that cuts the marital bond when the causes for incapacity become apparent. It refers to a serious psychological illness afflicting a party even before the celebration of the marriage. The evidence presented by the husband did not meet the required evidentiary standards to establish the wife's psychological incapacity.

PRINCIPLES:

• Psychological incapacity must be characterized by (a) a psychological illness; (b) the illness must have existed at the time of the marriage; (c) the illness must be grave enough to bring about the disability of the party to assume the essential obligations of marriage; (d) the illness must be rooted in the personality structure of the party; (e) the illness must be incurable and not merely temporary; (f) the illness must render the party truly incapable of fulfilling the marital obligations; and (g) the non-compliance with marital obligations must be continuous and must have persisted throughout the existence of the marriage.

• The essential marital obligations that must be violated or not complied with must be those embraced by Articles 68 up to 71 of the Family Code with regard to the husband and wife, as well as Articles 220, 221, and 225 of the same Code with regard to parents and their children.

• Interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines should be given great respect, as Article 36 of the Family Code was taken from Canon 1095 of the New Code of Canon Law.

• The prosecuting attorney or fiscal and the Solicitor General must appear as counsel for the state and issue a certification, stating their agreement or opposition to the petition, for a decision to be handed down. The Solicitor General shall discharge the equivalent function of the defensor vinculi contemplated under Canon 1095.

• Each case must be judged based on its own facts, not on a priori assumptions, predilections, or generalizations.

• The provision on declaration of nullity under Article 36 of the Family Code should be interpreted on a case-to-case basis, guided by experience, the findings of experts and researchers in psychological disciplines, and decisions of church tribunals.

• The requirement of "juridical antecedence" under Article 36 necessitates adequate credible evidence showing that the alleged psychological incapacity was already present at the inception of, or prior to, the marriage.

• Personal interviews with the subject of the psychiatric evaluation are important in determining psychological incapacity, as relying solely on information provided by one party may be biased and lack corroboration.

• A personal examination of the party alleged to be psychologically incapacitated is not mandatory in cases of annulment based on psychological incapacity.

• Information from persons with personal knowledge of the juridical antecedents may be helpful in determining a party's complete personality profile.

• Conclusions and generalizations on a spouse's psychological condition cannot be made based solely on information fed by one party.

• Article 36 of the Family Code refers to a serious psychological illness afflicting a party before the celebration of marriage.

• The badges of alleged psychological incapacity must be convincingly traced to the period before the marriage.

• Evidence must meet the required evidentiary standards to establish psychological incapacity under Article 36 of the Family Code.