- Petitioner
- Enrique Agraviador
- Respondent
- Erlinda Amparo-Agraviador
- Citation
- G.R. No. 170729
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Brion, J.
- Decided
- December 8, 2010
Whether respondent wife was psychologically incapacitated to comply with essential marital obligations under Article 36 of the Family Code
Summary
This Supreme Court case involved a petition for declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code. Husband Enrique sought to nullify his 1973 marriage to Erlinda, alleging she was psychologically incapacitated due to irresponsible behavior, extramarital affairs, and neglect of marital duties. The RTC initially granted the nullity based on a psychiatric evaluation diagnosing Mixed Personality Disorder. However, the Court of Appeals reversed, and the Supreme Court affirmed the reversal, finding insufficient evidence to establish psychological incapacity. The Court emphasized that the psychiatric evaluation failed to meet the stringent Molina guidelines requiring proof of juridical antecedence, gravity, and incurability. The decision reinforced that Article 36 requires downright incapacity, not mere refusal or difficulty in performing marital obligations, and that marriage's indissolubility must be protected except in the most serious cases of personality disorders clearly demonstrating utter inability to give meaning to marriage.