Republic v. Molina, G.R. No.

108763 February 13, 1997

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

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

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

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

essential obligations of marriage.

6. The essential marital obligations must be those embraced by Articles 68 up to 71 of the Family

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

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.

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

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.

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

8. The trial court must order the prosecuting attorney or fiscal and the Solicitor General to appear

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

as counsel for the state.

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

Marcos v. Marcos, 343 SCRA 755, October 19, 2000

FACTS: Brenda and Wilson first met sometime in 1980 when both of them were assigned at the

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

Malacaang Palace, she as an escort of Imee Marcos and he as a Presidential Guard of President
Ferdinand Marcos. They later on became sweethearts and got married and had 5 children. After the

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.

EDSA revolution, both of them sought a discharge from the military service. He engaged to different
business ventures but failed. She always urged him to look for work so that their children would see

The Court of Appeals denied the appeals and affirmed in toto the RTCs decision. Hence, this
petition.

him, instead of her, as the head of the family and a good provider. Due to his failure to engage in
any gainful employment, they would often quarrel and as a consequence, he would hit and beat

ISSUE: W/N psychological incapacity on the part of Reynaldo has been established

her. He would even force her to have sex with him despite her weariness. He would also inflict
physical harm on their children for a slight mistake and was so severe in the way he chastised them.

HELD: The marriage between Roridel and Reynaldo subsists and remains valid. What constitutes

Thus, for several times during their cohabitation, he would leave their house. In 1992, they were
already living separately. She did not want him to stay in their house anymore so when she saw him

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

in their house, she was so angry that she lambasted him. He then turned violent, inflicting physical
harm on her and even on her mother who came to her aid. She sought for nullity of their marriage

essential marital responsibilities and duties due to some psychological illness. Reynaldos action at
the time of the marriage did not manifest such characteristics that would comprise grounds for

on the ground of psychological incapacity. The Brenda submitted herself to psychologist Natividad
A. Dayan, Ph.D., for psychological evaluation. The court a quo found Wilson to be psychologically

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

incapacitated to perform his marital obligations mainly because of his failure to find work to
support his family and his violent attitude towards Brenda and their children. RTC granted the

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.

petition. CA reversed. Hence, this case.

8 Guidelines (Psychological Incapacity)

ISSUE: W/N there is a need for personal medical examination of respondent to prove psychological
incapacity? Whether the totality of evidence presented in this case show 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)

HELD: Personal medical or psychological examination of respondent is not a requirement for a

alleged in the complaint, (c) sufficiently proven by experts and (d) clearly explained in the decision.

declaration of psychological incapacity. Nevertheless, the totality of the evidence she presented

does not show such incapacity. Although SC is convinced that respondent failed to provide material
support to the family and may have resorted to physical abuse and abandonment, the totality of
these acts does not lead to a conclusion of psychological incapacity on his part. There is absolutely

Te v.Te, G.R. No. 161793, Feb. 13, 2009

FACTS: Edward Te first got a glimpse of respondent Rowena Ong Gutierrez Yu-Te in a gathering

no showing that his defects were already present at the inception of the marriage or that they are
incurable.

organized by the Filipino-Chinese association in their college. Edward was then initially attracted to
Rowenas close friend; but, as the latter already had a boyfriend, the young man decided to court

Chi Ming Tsoi v. CA, G.R. No. 119190, Jan. 16, 1997

Rowena. That was in January 1996, when petitioner was a sophomore student and respondent, a
freshman. In March 1996, or around three months after their first meeting, Rowena asked Edward

Facts: Ching married Gina on May 22, 1988 at the Manila Cathedral, Intramuros, Manila. After the
celebration and reception, they proceeded to the house of the Ching Ming Tsois mother. There

that they elope. At first, he refused, bickering that he was young and jobless. Her persistence,
however, made him relent. Thus, they left Manila and sailed to Cebu that month; he, providing their

they slept together on the same bed in the same room for the first night of their married life but
nothing happened, contrary to what she expected. The same happened to the subsequent nights. In

travel money and she, purchasing the boat ticket. However, Edwards P80,000.00 lasted for only a
month. In April 1996, they decided to go back to Manila. Rowena proceeded to her uncles house

an effort to have their honey moon in a private place where they can enjoy together during their
first week as husband and wife they went to Baguio City. But Ching brought along his mother, uncle

and Edward to his parents home. As his family was abroad, and Rowena kept on telephoning him,
threatening him that she would commit suicide, Edward agreed to stay with Rowena at her uncles

and nephew. During the time they were in Baguio, still no sexual intercourse happened because
Ching avoided her by taking a long walk during siesta time or by just sleeping on a rocking chair

place. On April 23, 1996, Rowenas uncle brought the two to a court to get married. He was then 25
years old, and she, 20. The two then continued to stay at her uncles place where Edward was

located at the living room. They slept together in the same room and on the same bed for 10
months but they never had sex. Gina claims that she did not even see her husbands private parts

treated like a prisonerhe was not allowed to go out unaccompanied. Her uncle also showed
Edward his guns and warned the latter not to leave Rowena. After a month, Edward escaped from

nor did he see hers. Because of this, they submitted themselves for medical examinations to Dr.
Eufemio Macalalag. Results showed that Gina is healthy, normal and still a virgin while Chings

the house of Rowenas uncle, and stayed with his parents. His family then hid him from Rowena and
her family whenever they telephoned to ask for him. In June 1996, Edward was able to talk to

examination was kept confidential. Gina claims that her husband is impotent, a closet homosexual
(she has seen him using an eyebrow pencil and sometimes the cleansing cream of his mother), and

Rowena. Unmoved by his persistence that they should live with his parents, she said that it was
better for them to live separate lives. They then parted ways. On January 18, 2000, Edward filed a

only married her to acquire or maintain his residency status here in the country and to publicly
maintain the appearance of a normal man. Ching denied the allegations. He claimed that if their

petition before the RTC for the annulment of his marriage to Rowena on the basis of her
psychological incapacity.

marriage shall be annulled by reason of psychological incapacity, the fault lies with Gina. He does
not want their marriage annulled because he loves her very much, he has no defect on his part and

ISSUE: Whether the marriage contracted is void on the ground of psychological incapacity.

he is physically and psychologically capable, and whatever differences they have are reconcilable
and curable. Ching admitted that they havent had sexual intercourse yet but it was because of

HELD: The parties whirlwind relationship lasted more or less six months. They met in January 1996,

Ginas refusal and whenever he caresses her private parts, she always removed his hands.

eloped in March, exchanged marital vows in May, and parted ways in June. The psychologist who
provided expert testimony found both parties psychologically incapacitated. Petitioners behavioral

ISSUE: Whether or not Ching is psychologically incapacitated to comply with the essential marital
obligations of marriage

pattern falls under the classification of dependent personality disorder (to make everyday decisions
without advice from others, and allows others to make most of his important decisions), and

RULING: The Supreme Court affirmed the decisions of the trial court and Court of Appeals in

respondents, that of the narcissistic and antisocial personality disorder (her disregard in the rights
of others, her abuse, mistreatment and control of others without remorse, and her tendency to

rendering as VOID the marriage entered into by Ching and Gina on May 22, 1988. One of the
essential marital obligations under the Family Code is to procreate children based on the universal

blame others, impulsive and domineering; she had no qualms in manipulating petitioner with her
threats of blackmail and of committing suicide). There is no requirement that the person to be

principle that procreation of children through sexual cooperation is the basic end of marriage. The
Supreme Court held that the prolonged refusal of a spouse to have sexual intercourse with his or

declared psychologically incapacitated be personally examined by a physician, if the totality of

evidence presented is enough to sustain a finding of psychological incapacity.

her spouse is considered a sign of psychological incapacity.