REPUBLIC v. GALANG (G.R. No. 168335, June 6, 2011)
It is not absolutely necessary to introduce expert opinion in a petition under Article 36 of the Family Code if the totality of evidence shows that psychological incapacity exists and its gravity, juridical antecedence, and incurability can be duly established. [Brenda Marcos vs. Marcos]
Instead of serving as a guideline, the Molina Doctrine unintentionally became a straightjacket; it forced all cases involving psychological incapacity to fit into and be bound by it. [Ngo Te vs. Yu-Te] In Ting vs. Velez-Ting, far from abandoning Molina, the Ngo Te case simply suggested the relaxation of its stringent requirements; the Ngo Te case merely stands for a more flexible approach in considering petitions for declaration of nullity of marriages based on psychological incapacity.
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