REPUBLIC OF THE PHILIPPINES

vs.

COURT OF APPEALS AND RORIDEL OLIVIANO MOLINA

G.R. No. 108763 February 13, 1997

PANGANIBAN, J.:

Facts: April 14, 1985, Roridel Oliviano married Reynaldo Molina at San Agustin church in Manila. Said
union bore a son named Andre Oliviano Molina. Reynaldo, showing signs of immaturity and
irresponsibility as a husband and as a father at the early stage of their marriage, exhibited by his
preference to spend time with his peers and friends on whom he squandered his money, dependency on
his parents for aid and assistance, dishonesty to his wife regarding their finances, and being relieved from
his job, resulting quarrels between them. On October 1986 the couple had a very intense argument
causing their relationship to be estranged. By March 1987, Roridel resigned from her job in Manila and
went to live with her parents in Baguio. A few weeks later, Reynaldo left his wife and son and abandoned
them since then.

On the grounds of psychological incapability of Reynaldo in complying with his marital obligations, Roridel
filed a petition to have their marriage void on August 14, 1985. Such claim was supported by the
respondent wifes testimony as well as that of her friends including Rose G. Lalas, a social worker and Dr.
Teresita Hidalgo-Sison, a psychiatrist in Baguio General Hospital. By May 14, 1991, the trial court rendered
judgment declaring the marriage void. The Republic through the Solicitor Generals appeal, insisting the
erroneous and incorrect interpretation of the phrase psychological incapacity was denied by the Court
of Appeals, affirming the Trial Courts decision.

Issues: Whether or not the marriage of Roridel and Reynaldo be declared null and void on the grounds of
psychological incapacity.

Rulings: There having been no clear showing of psychological incapability, but rather a mere display of
irreconcilable differences and conflicting personalities, the supreme court granted the petition and
reversed the decision, concluding that the marriage between Roridel and Reynaldo remains valid and
subsisting.

The majority opinion, overturning that of the Court of Appeals which affirmed the Regional Trial Courts
ruling upheld that the opposing personalities is not equivalent to psychological incapacity. It is not
enough to prove that the parties failed in meeting their duties and responsibilities as married persons; it
is essential that they must be shown to be incapable of doing so, due to psychological illness.

The court promulgated guidelines in the interpretation and application of Article 36 of the Family Code
that was used for the deliberations of the case at bar. They are as follows:

(1) The proof to show the nullity of the marriage belongs to the plaintiff.
(2) The root cause of psychological incapacity must be medically or clinically identified and proven.
(3) The incapacity must be proven to exist at the time of celebration of marriage.
(4) Such incapacity must be medically permanent or incurable.
(5) Such illness be grave so as to disable the party to assume essential obligations of marriage.
(6) The essential marital obligations must be those embraced by Articles 68 to 71 of the Family Code
as regards to 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 must
be respected.
(8) The trial court must order prosecuting attorney and the Solicitor General to appear as counsel for
the state.