FACTS: Roridel and
Reynaldo were married on April 14, 1985 and begot a son. After a year of
marriage, Reynaldo showed signs of "immaturity and irresponsibility"
as a husband and a father since 1) he preferred to spend more time with his
peers and friends on whom he squandered his money; 2) he depended on his
parents for aid and assistance; and 3) he was never honest with his wife in
regard to their finances, resulting in frequent quarrels between them. When
Reynaldo was relieved from his job, Roridel had been the sole breadwinner of
the family. In October 1986 the couple had a very intense quarrel, as a result
of which their relationship was estranged. In March 1987, Roridel resigned from
her job in Manila and went to live with her parents in Baguio City. A few weeks
later, Reynaldo left Roridel and their child, and had since then abandoned
them. Reynaldo admitted that he and Roridel could no longer live together as
husband and wife, but contended that their misunderstandings and frequent
quarrels were due to (1) Roridel's strange behavior of insisting on maintaining
her group of friends even after their marriage; (2) Roridel's refusal to
perform some of her marital duties such as cooking meals; and (3) Roridel's
failure to run the household and handle their finances. On 16 August 1990,
Roridel filed a petition for declaration of nullity of her marriage to Reynaldo
Molina. Evidence for Roridel consisted of her own testimony, that of two of her
friends, a social worker, and a psychiatrist of the Baguio General Hospital and
Medical Center. Reynaldo did not present any evidence as he appeared only
during the pre-trial conference. RTC declared the marriage void. The Solicitor
General appealed to the Court of Appeals. The Court of Appeals denied the
appeals and affirmed in toto the RTC’s decision. Hence, this petition.
ISSUE: W/N
psychological incapacity on the part of Reynaldo has been established
HELD: The marriage
between Roridel and Reynaldo subsists and remains valid. What constitutes psychological incapacity is
not mere showing of irreconcilable differences and conflicting personalities. It is indispensable that the parties must
exhibit inclinations which would not meet the essential marital responsibilities
and duties due to some psychological illness.
Reynaldo’s action at the time of the marriage did not manifest such
characteristics that would comprise grounds for psychological incapacity. The evidence shown by Roridel merely showed
that she and her husband cannot get along with each other and had not shown
gravity of the problem neither its juridical antecedence nor its incurability. In addition, the expert testimony by Dr Sison
showed no incurable psychiatric disorder but only incompatibility which is not
considered as psychological incapacity.
8 Guidelines
(Psychological Incapacity)
1. The burden of proof
to show the nullity of the marriage belongs to the plaintiff.
2. The root cause of
the psychological incapacity must be (a) medically or clinically identified,
(b) alleged in the complaint, (c) sufficiently proven by experts and (d)
clearly explained in the decision.
3. The incapacity must
be proven to be existing at "the time of the celebration" of the
marriage.
4. Such incapacity
must also be shown to be medically or clinically permanent or incurable
5. Such illness must
be grave enough to bring about the disability of the party to assume the
essential obligations of marriage.
6. The essential
marital obligations must be those embraced by Articles 68 up to 71 of the
Family Code as regards the husband and wife as well as Articles 220, 221 and
225 of the same Code in regard to parents and their children.
7. Interpretations
given by the National Appellate Matrimonial Tribunal of the Catholic Church in
the Philippines, while not controlling or decisive, should be given great
respect by our courts.
8. The trial court must order the prosecuting
attorney or fiscal and the Solicitor General to appear as counsel for the
state.
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