Republic of the Philippines vs.

Erlinda Matias Dagdag

Facts: Plaintiff Erlinda Matias married Avelino Dagdag in 1975 and they had two
children. A week after the wedding, Avelino would disappear for months. When he is
with his family, he would be spending time drinking with friends and inflicted
physical violence on Erlina. In 1983, Avelino left his family and Erlina later learned
that he was imprisoned but escaped from jail.

Issue: Whether or not the trial court and CA erred in declaring the marriage of
Avelino and Erlinda void on the ground of psychological incapacity of the husband?
Ruling: Yes. The judgment of the trial court and CA are reversed. Erlinda failed to
comply with the required evidentiary requirements. Erlinda failed to comply with
Guideline No. 2 as the court had laid down in Republic vs. Court of Appeals and
Molina. Psychological incapacity must be medically or clinically identified and
sufficiently proven by experts. No psychiatrist or medical doctor testified to the
alleged psychological incapacity of her husband. The allegation that the husband is
a fugitive from justice was not sufficiently proven and the investigating prosecutor
was not given an opportunity to present refuting evidence.