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Art 36 FC ISSUES:
In fine, respondent argued that apart from her non- Interpretations given by the National Appellate
disclosure of a child prior to their marriage, the other Matrimonial Tribunal of the Catholic Church in the
lies attributed to her by petitioner were mostly hearsay Philippines, while not controlling or decisive, should be
and unconvincing. Her stance was that the totality of given great respect by our courts.
We find that the present case sufficiently satisfies the incapacity be shown to be medically or clinically
guidelines in Molina. permanent or incurable.
Second. The root cause of respondent's psychological respondent's aberrant behavior remained unchanged,
incapacity has been medically or clinically identified, as she continued to lie, fabricate stories, and
alleged in the complaint, sufficiently proven by experts, maintained her excessive... jealousy. From this fact, he
and clearly explained in the trial court's decision. draws the conclusion that respondent's condition is
incurable.
Third. Respondent's psychological incapacity was
established to have clearly existed at the time of and respondent's psychosis is quite grave, and a cure
even before the celebration of marriage. She fabricated thereof a remarkable feat.
friends and made up letters from fictitious characters
well before she married petitioner The requirement... that psychological incapacity must
be shown to be medically or clinically permanent or
Fourth. The gravity of respondent's psychological incurable is one that necessarily cannot be divined
incapacity is sufficient to prove her disability to assume without expert opinion.
the essential obligations of marriage. It is immediately
discernible that the parties had shared only a little over From the totality of the evidence, we are sufficiently
a year of cohabitation before the... exasperated convinced that the incurability of respondent's
petitioner left his wife. psychological incapacity... has been established by the
petitioner.
Indeed, a person unable to distinguish between fantasy
and reality would similarly be unable to comprehend
the legal nature of the marital bond, much less its REPUBLIC V MELGAR (2006)
psychic meaning, and the corresponding obligations
attached to marriage, including parenting. PONENTE: Austria-Martinez, J.
1. key facts: The parties’ whirlwind relationship lasted ABLAZA V REPUBLIC OF THE PH (2010)
more or less six (6) months. They met in January
1996, eloped in March, exchanged marital vows in
May, and parted ways in June. The psychologist who VOID MARRIAGES; FINAL JUDGMENT
provided expert testimony found both parties
psychologically incapacitated. Petitioner’s PEOPLE V MENDOZA (1954)
behavioral pattern falls under the classification of
dependent personality disorder, and respondent’s, TOLENTINO V PARAS (1983)
that of the narcissistic and antisocial personality WIEGEL V SEMPIO-DY (1986)
disorder.
2. Article 36. A marriage contracted by any party who, TERRE V TERRE (1992)
at the time of the celebration, was psychologically ATIENZA V BRILLANTES (1995)
incapacitated to comply with the essential marital
obligations of marriage, shall likewise be void even APIAG V CANTERO (1997)
if such incapacity becomes manifest only after its
solemnization.
3. Psychological incapacity does not refer to mental VOID MARRIAGES; EFFECTS OF NULLITY
faculties and has nothing to do with consent; it
refers to obligations attendant to marriage.” Art 43 FC.
4. Petitioner being afflicted with dependent
personality disorder that hinders him from Art 44 FC.
assuming marital obligations and respondent being Art 50 FC.
afflicted with antisocial personality disorder makes
her unable to assume the same. Art 51 FC.
5. Both parties being afflicted with grave, severe and
Art 52 FC.
incurable psychological incapacity, the precipitous
Art 53 FC.
Art 54 FC.