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G.R. No.

108763 February 13, 1997


On the 14th of April 1984, Roridel Olaviano married Reynaldo Molina in Manila, and gave birth
to a son a year after. Reynaldo showed signs of immaturity and irresponsibility on the early
stages of the marriage, observed from his tendency to spend time with his friends, squandering
his money with them, being used to his dependency from his parents, while continuously being
dishonesty on matters involving his finances. In 1986 Roridel became the sole breadwinner of
the family when Reynaldo was relieved of his job. In March 1987, Roridel resigned from her job
in Manila and proceeded to Baguio City. Reynaldo left her and their child a week later and the
couple is separated-in-fact for more than three years.
On 16 August 1990, Roridel filed a verified 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. On
14 May 1991, the trial court rendered judgment declaring the marriage void. The Solicitor
General appealed to the Court of Appeals. The Court of Appeals denied the appeals and affirmed
in toto the RTCs decision. Hence, the present recourse.

ISSUE: Whether or not the marriage is void on the ground of psychological incapacity.
The marriage of Roridel and Reynaldo remains valid. Court prescribes that a marriage
wrought by psychological incapacity is one plagued by true mental incapacity between one or
both of the parties. Mere manifestation of irreconcilable differences and conflicts natural to
husbands and wives, and the parties unwilling behaviour to rectify and correct the behaviour
cannot be considered as psychological incapacity on one of its members. It is indispensable to
the case that the parties 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 be material grounds for psychological
incapacity. The evidence shown brought by Roridel merely showed that she and her husband
could not make proper adjustments in favour of the other and had not shown the gravity of the
problem neither its juridical antecedence nor its incurability. What it made manifest was a

refusal to work through difficulties and negligence to address marital issues that were curable. 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.