G.R. No. 161793, 13 February 2009
Petitioner Edward Te first met respondent Rowena Te in a gathering organized by the Filipino-Chinese association in their college. Initially, he was attracted to Rowena’s close friend but, as the latter already had a boyfriend, the young man decided to court Rowena, which happened in January 1996. It was Rowena who asked that they elope but Edward refused bickering that he was young and jobless.
Her persistence, however, made him relent. They left Manila and sailed to Cebu that month; he, providing their travel money of P80,000 and she, purchasing the boat ticket.
They decided to go back to Manila in April 1996. Rowena proceeded to her uncle’s house and Edward to his parents’ home. Eventually they got married but without a marriage license. Edward was prohibited from getting out of the house unaccompanied and was threatened by Rowena and her uncle. After a month, Edward escaped from the house, and stayed with his parents. Edward’s parents wanted them to stay at their house but Rowena refused and demanded that they have a separate abode. In June 1996, she said that it was better for them to live separate lives and they then parted ways.
After four years in January 2000, Edward filed a petition for the annulment of his marriage to Rowena on the basis of the latter’s psychological incapacity.
Whether the marriage contracted is void on the ground of psychological incapacity.
The Supreme Court ruled that admittedly, the SC may have inappropriately imposed a set of rigid rules in ascertaining Psychological Incapacity in the Molina case. So much so that the subsequent cases after Molina were ruled accordingly to the doctrine set therein. And that there is not much regard for the law’s clear intention that each case is to be treated differently, as “courts should interpret the provision on a case-to-case basis; guided by experience, the findings of experts and researchers in psychological disciplines, and by decisions of church tribunals.” The SC however is not abandoning the Molina guidelines, the SC merely reemphasized that there is need to emphasize other perspectives as well which should govern the disposition of petitions for declaration of nullity under Article 36 such as in the case at bar. The principle that each case must be judged, not on the basis of a priori assumptions, predilections or generalizations but according to its own facts. And, to repeat for emphasis, courts should interpret the provision on a case-to-case basis; guided by experience, the findings of experts and researchers in psychological disciplines, and by decisionsofchurchtribunals.
The SC then ruled that the marriage of Kenneth and Rowena is null and void due to both parties’ psychological disorder as evidenced by the finding of the expert psychologist. Both parties being afflicted with grave, severe and incurable psychological incapacity, Kenneth cannot assume the essential marital obligations of living together, observing love, respect and fidelity and rendering help and support, for he is unable to make everyday decisions without advice from others. He is too dependent on others. Rowena cannot perform the essential marital obligations as well due to her intolerance and impulsiveness.
* Case digest by Kristine Camille B. Gahuman , LLB-1, Andres Bonifacio Law School, SY 2017-2018