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REPUBLIC v. ERLINDA MATIAS DAGDAG

This case has been cited 8 times or more.

	GR No. 159594 2012-11-12	REPUBLIC v. CA BERSAMIN, J.
The foregoing pronouncements in Santos and Molina have remained as the precedential guides in deciding cases grounded on the psychological incapacity of a spouse. But the Court has declared the existence or absence of the psychological incapacity based strictly on the facts of each case and not on a priori assumptions, predilections or generalizations.[20] Indeed, the incapacity should be established by the totality of evidence presented during trial,[21] making it incumbent upon the petitioner to sufficiently prove the existence of the psychological incapacity.[22]
	GR No. 157649 2012-11-12	ARABELLE J. MENDOZA v. REPUBLIC BERSAMIN, J.
The CA held the testimonies of petitioner's witnesses insufficient to establish Dominic's psychological affliction to be of such a grave or serious nature that it was medically or clinically rooted. Relying on the pronouncements in Republic v. Dagdag,[13] Hernandez v. Court of Appeals[14] and Pesca v. Pesca,[15] the CA observed: In her testimony, petitioner described her husband as immature, deceitful and without remorse for his dishonesty, and lack of affection. Such characteristics, however, do not necessarily constitute a case of psychological incapacity. A person's inability to share or take responsibility, or to feel remorse for his misbehavior, or even to share his earnings with family members, are indicative of an immature mind, but not necessarily a medically rooted psychological affliction that cannot be cured.
	GR No. 180668 2009-05-26	MARIETA C. AZCUETA v. REPUBLIC LEONARDO-DE CASTRO, J.
However, in more recent jurisprudence, we have observed that notwithstanding the guidelines laid down in Molina, there is a need to emphasize other perspectives as well which should govern the disposition of petitions for declaration of nullity under Article 36.[14] Each case must be judged, not on the basis of a priori assumptions, predilections or generalizations but according to its own facts. In regard to psychological incapacity as a ground for annulment of marriage, it is trite to say that no case is on "all fours" with another case. The trial judge must take pains in examining the factual milieu and the appellate court must, as much as possible, avoid substituting its own judgment for that of the trial court.[15] With the advent of Te v. Te,[16] the Court encourages a reexamination of jurisprudential trends on the interpretation of Article 36 although there has been no major deviation or paradigm shift from the Molina doctrine.
	GR NO. 147824 2007-08-02	ROSA YAP PARAS v. JUSTO J. PARAS SANDOVAL-GUTIERREZ, J.
Interestingly, in the same year (2000) that Marcos was decided, the Court backtracked a bit when it held in Republic v. Dagdag[44] that, "the root cause of psychological incapacity must be medically or clinically identified and sufficiently proven by experts" and this requirement was not deemed complied with where no psychiatrist or medical doctor testified on the alleged psychological incapacity of one party.
	GR NO. 155800 2006-03-10	LEONILO ANTONIO v. MARIE IVONNE F. REYES TINGA, J.
We likewise observed in Republic v. Dagdag:[71]
	GR No. 158896 2004-10-27	JUANITA CARATING-SIAYNGCO v. MANUEL SIAYNGCO CARPIO, J.
Our pronouncement in Republic v. Dagdag[41] is apropos. There, we held that whether or not psychological incapacity exists in a given case calling for the declaration of the nullity of the marriage depends crucially on the facts of the case. Each case must be closely scrutinized and judged according to its own facts as there can be no case that is on "all fours" with another. This, the Court of Appeals did not heed.
	GR No. 151867 2004-01-29	DAVID B. DEDEL v. CA YNARES-SATIAGO, J.
The difficulty in resolving the problem lies in the fact that a personality disorder is a very complex and elusive phenomenon which defies easy analysis and definition. In this case, respondent's sexual infidelity can hardly qualify as being mentally or psychically ill to such an extent that she could not have known the obligations she was assuming, or knowing them, could not have given a valid assumption thereof.[14] It appears that respondent's promiscuity did not exist prior to or at the inception of the marriage. What is, in fact, disclosed by the records is a blissful marital union at its celebration, later affirmed in church rites, and which produced four children.
	GR No. 137590 2001-03-26	FLORENCE MALCAMPO-SIN v. PHILIPP T. SIN PARDO, J.
In Republic of the Philippines v. Erlinda Matias Dagdag,[19] while we upheld the validity of the marriage, we nevertheless characterized the decision of the trial court as "prematurely rendered" since the investigating prosecutor was not given an opportunity to present controverting evidence before the judgment was rendered. This stresses the importance of the participation of the State.