TL;DR

The Supreme Court ruled that allegations of psychological incapacity in a petition for nullity of marriage were sufficient to proceed with a trial. The Court emphasized that the determination of psychological incapacity is a factual matter best decided by the trial court after presentation of evidence, and the allegations in the petition adequately complied with the guidelines set forth in Republic v. Court of Appeals (the Molina doctrine). This means the case can move forward, allowing both parties to present evidence to support or refute the claims, ultimately deciding whether the marriage should be declared null based on psychological incapacity.

Unraveling the Psyche: Can Allegations of Incapacity Dissolve a Marriage?

In the case of Danilo A. Aurelio v. Vida Ma. Corazon P. Aurelio, the Supreme Court grappled with the crucial question of whether a petition for declaration of nullity of marriage, based on psychological incapacity, contained sufficient allegations to warrant a trial. This case highlights the application of Article 36 of the Family Code, which allows for the nullification of a marriage if one or both parties were psychologically incapacitated to comply with the essential marital obligations at the time of the marriage. The Court’s decision hinged on whether the respondent’s petition met the standards set by the landmark Molina doctrine, a set of guidelines established to aid courts in evaluating such cases.

The legal framework for determining psychological incapacity is rooted in Article 36 of the Family Code. This provision states:

Article 36. A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void, even if such incapacity becomes manifest only after its solemnization.

To provide guidance in interpreting and applying this article, the Supreme Court laid out the Molina guidelines. These guidelines require that the root cause of the incapacity be medically or clinically identified, alleged in the complaint, sufficiently proven by experts, and clearly explained in the decision. It also states that the incapacity must be proven to be existing at the time of the marriage celebration and shown to be medically or clinically permanent or incurable, along with the illness being grave enough to disable the party from fulfilling the essential obligations of marriage.

In this case, the petitioner, Danilo Aurelio, argued that the respondent’s petition failed to meet several of the Molina guidelines, specifically those related to the root cause of the incapacity, the gravity of the illness, and the identification of non-complied marital obligations. The Court of Appeals (CA), however, affirmed the trial court’s decision to deny the petitioner’s motion to dismiss, finding that the respondent’s complaint sufficiently stated a cause of action. The Supreme Court agreed with the CA, emphasizing that a review of the petition showed compliance with the requirements of the Molina doctrine.

The Court highlighted that the respondent’s petition discussed the family backgrounds of both parties as the root causes of their psychological incapacity, which were clinically identified by a competent psychologist. Further, the petition alleged that both parties suffered from illnesses of such grave nature as to disable them from assuming the essential obligations of marriage, including Histrionic Personality Disorder with Narcissistic Features (for the respondent) and Passive Aggressive (Negativistic) Personality Disorder (for the petitioner). The petition also identified the essential marital obligations that were not complied with, falling under Article 68 of the Family Code, which pertains to mutual love, respect, fidelity, help, and support.

The Supreme Court underscored that the determination of whether the parties are indeed psychologically incapacitated is a matter for the trial court to decide after the presentation of evidence. The Molina guidelines contemplate a situation where evidence has been presented, witnesses have testified, and the court has reached a decision after a due hearing. The Court thus ruled that the Regional Trial Court (RTC) did not commit grave abuse of discretion in denying the petitioner’s motion to dismiss, as the allegations in the respondent’s petition were sufficient to proceed with a trial on the merits. In essence, the Court affirmed that the case should move forward to allow for a full presentation of evidence and a thorough evaluation of the claims of psychological incapacity.

FAQs

This case underscores the importance of meticulously crafting petitions for nullity of marriage based on psychological incapacity, ensuring compliance with the Molina guidelines. It also highlights the trial court’s crucial role in evaluating the evidence and determining whether the alleged incapacity truly exists and warrants the dissolution of the marriage.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Danilo A. Aurelio v. Vida Ma. Corazon P. Aurelio, G.R. No. 175367, June 06, 2011