G.R. No. 173294 ; February 27, 2008
Renne Enrique Bier, petitioner, vs. Ma. Lourdes A. Bier and The Republic of the Philippines, respondents.

FACTS

Petitioner Renne Enrique Bier and respondent Ma. Lourdes Bier married in 1992. For the first three years, the marriage was harmonious, with Lourdes described as a loving and caring wife. However, after this period, petitioner alleged that respondent underwent a drastic change in behavior. She became aloof, refused sexual relations, neglected household duties, and frequently left home for days without explanation. She also allegedly became an alcoholic and a chain-smoker. In 1997, respondent left for the United States and petitioner had no further contact with her.
In 1998, petitioner filed a petition to declare his marriage null and void on the ground of respondent’s psychological incapacity under Article 36 of the Family Code. The Regional Trial Court granted the petition. The Republic, through the Office of the Solicitor General, appealed. The Court of Appeals reversed the RTC decision, holding that petitioner failed to comply with the guidelines established in the case of Republic v. Molina, specifically the requirement to medically or clinically identify the root cause of the alleged psychological incapacity.

ISSUE

Whether the Court of Appeals correctly reversed the RTC decision declaring the marriage null and void on the ground of psychological incapacity.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA decision, denying the petition. The Court reiterated that while the Molina guidelines are not inflexible, a petition for nullity under Article 36 must still prove that the psychological incapacity is a serious, grave, and incurable condition rooted in a psychological or mental illness existing at the time of the marriage. The incapacity must be more than mere irreconcilable differences, refusal to have sexual relations, or neglect of marital duties.
In this case, petitioner’s evidence merely described respondent’s post-marital behavior—her neglect, abandonment, and lifestyle changes. He failed to demonstrate that these acts were manifestations of a psychological disorder that was grave, medically identified, and incurable. Crucially, there was no expert testimony or clinical evidence to establish that respondent’s alleged condition had a psychological or psychiatric root cause that existed at the inception of the marriage. The totality of the evidence presented only showed marital strife and a failed marriage, which is insufficient for a declaration of nullity. Consequently, the marriage remains valid and subsisting.