Republic vs CA and Molina

Republic vs. CA and Molina

G.R. No. 108763 February 13, 1997

FACTS:

The case at bar challenges the decision of CA affirming the marriage of the respondent Roridel
Molina to Reynaldo Molina void in the ground of psychological incapacity. The couple got
married in 1985, after a year, Reynaldo manifested signs of immaturity and irresponsibility
both as husband and a father preferring to spend more time with friends whom he squandered
his money, depends on his parents for aid and assistance and was never honest with his wife in
regard to their finances. In 1986, the couple had an intense quarrel and as a result their
relationship was estranged. Roridel quit her work and went to live with her parents in Baguio
City in 1987 and a few weeks later, Reynaldo left her and their child. Since then he
abandoned them.

ISSUE: Whether or not the marriage is void on the ground of psychological incapacity.

HELD:

The marriage between Roridel and Reynaldo subsists and remains valid. What constitutes
psychological incapacity is not mere showing of irreconcilable differences and confliction
personalities. It is indispensable that the parties must exhibit inclinations which would not
meet the essential marital responsibilites 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 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.

The following are the guidelines as to the grounds of psychological incapacity laid set forth in
this case:
burden of proof to show nullity belongs to the plaintiff
root causes of the incapacity must be medically and clinically inclined
such incapacity should be in existence at the time of the marriage
such incapacity must be grave so as to disable the person in complying with the
essentials of marital obligations of marriage
such incapacity must be embraced in Art. 68-71 as well as Art 220, 221 and 225 of the
Family Code
decision of the National Matrimonial Appellate Court or the Catholic Church must be
respected
court shall order the prosecuting attorney and the fiscal assigned to it to act on behalf of
the state.

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Tenchavez vs Escao
15 Phil 355
Torts and Damages When Liability for Quasi Delict Arises Unfounded Suit
In February 1948, Tenchavez and Escao secretly married each other and of course without
the knowledge of Escaos parents who were of prominent social status. The marriage was
celebrated by a military chaplain. When Escaos parents learned of this, they insisted a
church wedding to be held but Escao withdrew from having a recelebration because she
heard that Tenchavez was having an affair with another woman. Eventually, their relationship
went sour; 2 years later, Escao went to the US where she acquired a decree of absolute
divorce and she subsequently became an American citizen and also married an American.
In 1955, Tenchavez initiated a case for legal separation and further alleged that Escaos
parents dissuaded their daughter to go abroad and causing her to be estranged from him
hence hes asking for damages in the amount of P1,000,000.00. The lower court did not
grant the legal separation being sought for and at the same time awarded a P45,000.00
worth of counter-claim by the Escaos.

ISSUE: Whether or not damages should be awarded to either party in the case at bar

HELD: Yes.
On the part of Tenchavez:
His marriage with Escao was a secret one and the failure of said marriage did not result to
public humiliation; that they never lived together and he even consented to annulling the
marriage earlier (because Escao filed for annulment before she left for the US but the same
was dismissed due to her non-appearance in court); that he failed to prove that Escaos
parents dissuaded their daughter to leave Tenchavez and as such his P1,000,000.00 claim
cannot be awarded. HOWEVER, by reason of the fact that Escao left without the knowledge
of Tenchavez and being able to acquire a divorce decree; and Tenchavez being unable to
remarry, the SC awarded P25,000.00 only by way of moral damages and attorneys fees to
be paid by Escao and not her parents.
On the part of Escaos parents:
It is true that the P1,000,000.00 for damages suit by Tenchavez against the Escaos is
unfounded and the same must have wounded their feelings and caused them anxiety, the
same could in no way have seriously injured their reputation, or otherwise prejudiced them,
lawsuits having become a common occurrence in present society. What is important, and has
been correctly established in the decision of the lower court, is that they were not guilty of
any improper conduct in the whole deplorable affair. The SC reduced the damages awarded
from P45,000.00 to P5,000.00 only.

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