Te vs. Te[re: Molina Doctrine] G.R. No.

161793, February 13, 2009

FACTS: Edward Kenneth Te & Rowena Te decided to elope in Cebu. However, after one
month, their money, accommodation & daily sustenance fast depleted, not being able to
find jobs. They decided to go back to Manila. Rowena stayed in her uncle’s house. Due to
Rowena’s threat of suicide, Edward agreed to live w/her at her uncle’s house. They get
married. After a month, petr escape from uncle’s house because he was under threat by the
uncle not to leave respondent. When petr & respondent were able to talk again, respondent
said it was better for them to live separate lives, to wit they separated. Four years later,
petitioner filed a petition for the annulment of his marriage to respondent on the basis of
psychological incapacity. A clinical psychologist who examined the petitioner found both
parties to be psychologically incapacitated. The RTC declared the marriage null & void, w/c
the CA reversed & set aside. Thus, this petition.
ISSUE: WON the marriage is null & void on the ground of psychological incapacity.
HELD: Yes. In ruling that the doctrine in Rep vs CA was inapplicable, the crt declared that
cases of psychological incapacity shld be decided on the basis of a priori assumptions,
predictions & generalizations but accdg to its own facts. Crts shld interpret the provn on a
case to case basis; guided by experience, the findings of experts & researchers in
psychological disciplines & by decisions of church tribunals. Although it does not suggest
the abandonment of the Molina Doctrine, it ruled that said doctrine has become a strait
jacket or confines to fit into & be bound by it & applying said doctrine has allowed
disgnosed sociopaths, schizophrenics, nymphomaniacs, narcissists & the like to
continuously debase & pervert the sanctity of marriage.
In this case, the crt finds the psychological evaluation made by the expert witness of the
seriousness of the diagnosis & the gravity of the disorders.
Thus, the marriage of the parties is null & void on the ground of both parties
psychologicall incapacity.