Republic v. Court of Appeals and Molina

Summary

The Supreme Court En Banc reversed lower courts that declared a marriage void ab initio based on psychological incapacity under Article 36 of the Family Code. The case involved Roridel and Reynaldo Molina who married in 1985 but separated after marital problems including Reynaldo's alleged immaturity, irresponsibility, and abandonment. While lower courts found psychological incapacity based on conflicting personalities, the Supreme Court held that mere irreconcilable differences do not constitute psychological incapacity, which must be a grave, incurable mental condition existing at the time of marriage. The Court established comprehensive 8-point guidelines for Article 36 cases, requiring medical identification of root causes, expert proof, and demonstration of actual incapacity rather than mere difficulty in performing marital obligations. The decision emphasized that marriage is constitutionally inviolable and should be protected from dissolution at the parties' whim, declaring the marriage valid and subsisting.