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    Republic of The Philippines v. CA and Molina Facts

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    Charmaine Bagui Magsino
    The Supreme Court reversed the lower courts' rulings and declared the marriage of Roridel and Reynaldo valid. The Court found that the case involved normal incompatibility between the spouses rather than psychological incapacity, which must be a serious disorder existing at the time of marriage. Irreconcilable differences and conflicting personalities do not constitute incapacity. The characteristics of gravity, permanence, and inability to comply with marital obligations were not present. The Court established guidelines for properly interpreting and applying psychological incapacity, including requiring identification and proof of the medical condition.

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    Republic of The Philippines v. CA and Molina Facts

    Uploaded by

    Charmaine Bagui Magsino
    35 views1 page
    The Supreme Court reversed the lower courts' rulings and declared the marriage of Roridel and Reynaldo valid. The Court found that the case involved normal incompatibility between the spouses rather than psychological incapacity, which must be a serious disorder existing at the time of marriage. Irreconcilable differences and conflicting personalities do not constitute incapacity. The characteristics of gravity, permanence, and inability to comply with marital obligations were not present. The Court established guidelines for properly interpreting and applying psychological incapacity, including requiring identification and proof of the medical condition.

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    LAW

    Original Title

    Molina Digest

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    The Supreme Court reversed the lower courts' rulings and declared the marriage of Roridel and Reynaldo valid. The Court found that the case involved normal incompatibility between the spouses rather than psychological incapacity, which must be a serious disorder existing at the time of marriage. Irreconcilable differences and conflicting personalities do not constitute incapacity. The characteristics of gravity, permanence, and inability to comply with marital obligations were not present. The Court established guidelines for properly interpreting and applying psychological incapacity, including requiring identification and proof of the medical condition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    35 views1 page

    Republic of The Philippines v. CA and Molina Facts

    Uploaded by

    Charmaine Bagui Magsino
    The Supreme Court reversed the lower courts' rulings and declared the marriage of Roridel and Reynaldo valid. The Court found that the case involved normal incompatibility between the spouses rather than psychological incapacity, which must be a serious disorder existing at the time of marriage. Irreconcilable differences and conflicting personalities do not constitute incapacity. The characteristics of gravity, permanence, and inability to comply with marital obligations were not present. The Court established guidelines for properly interpreting and applying psychological incapacity, including requiring identification and proof of the medical condition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    Republic of the Philippines v.

    CA and Molina

    FACTS
    Respondent Roridel Molina married Reynaldo Molina on April 14, 1985. After a year of
    marriage, Reynaldo showed signs of “immaturity and irresponsibility” as a husband and a father
    exhibited by his preference to spend time with friends, squandering money, dependence on his
    parents and dishonesty involving finances. Inevitably, this resulted in quarrels and by March 1987,
    Roridel quit her job and moved in with her parents in Baguio. Reynaldo left her and their child a few
    weeks thereafter.
    On Aug. 16, 1990, Roridel filed a verified petition for declaration of nullity of marriage on the
    grounds of psychological incapacity of the husband. The trial court declared the marriage void, which
    the CA affirmed in toto; hence, the petition for certiorari.

    ISSUE
    Whether there is psychological incapacity
    HELD
    No. The case of Roridel and Reynaldo merely constituted incompatibility among the estranged
    spouses. The law intended to confine the meaning of psychological incapacity only to the most
    serious cases of personality disorders that must have existed at the time marriage is celebrated.
    Irreconcilable differences or conflicting personalities are not incapacities that would hinder the
    fulfillment of the essential marital obligations of the parties. The characteristics of gravity, judicial
    antecedence and incurability are not present in the case.

    Due to the improper interpretations and applications arrived at by the lower courts on this
    particular issue, the SC found it wise to construe the law and lay down guidelines in interpretation
    and application of Art. 36. Here, the SC sought the help of two amici curiae – considered an external
    aid in statutory construction. The guidelines set forth are thus: (1) the burden of proof belongs to the
    plaintiff; (2) the root cause of psychological incapacity must be medically or clinically identified,
    alleged in the complaint, sufficiently proven by expert, and clearly explained in the decision; (3) the
    incapacity must be proven to be existing at the time of the celebration of marriage; (4) the incapacity
    must be medically or clinically permanent or incurable; (5) such illness must be grave enough to
    disable fulfillment of essential marital obligations; (6) the essential marital obligation must be
    embraced by Articles 68 to 71 of the Family Code as regards husband and wife, and Articles 220 to
    225 of the same code as regards parents and their children; (7) interpretation made by the National
    Appellate Matrimonial Tribunal of the Catholic Church are to be given great weight; and (8) the fiscal
    and the Solicitor-General must appear as counsel for the State.

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