Bicameral Conference Committee Meeting, Committee on Revision of Laws J/W Committee on Women, March 17, 1997. 111 Sub-committee on Disadvantaged Women (Committee on Women) JT. Sub-committee on Criminal Laws Committee on Revision of Laws), November 15, 1995. 112 113 Committee on Revision of Laws J/W Committee on Women, January 29, 1996. 114 ANTI-VIOLENCE AGAINST WOMEN AND THEIR CHILDREN ACT OF 2004. http://pcw.gov. ph/statistics/201304/statistics-vio lence-against-filipino-women, last visited on March 18, 2014. 115 116 CA rollo, pp. 150-151. 117 CEDAW, Article 5, Part I. UN General Assembly, December 20, 1993. http://www.un.org/documents/ga/res/48/a48rl 04.htm, last accessed on April 1, 2014. 118 119 Id. 120 Universal Declaration of Human Rights, Article I: All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood. 121 UN Declaration on the Elimination of Violence Against Women, Article 4: States should condemn violence against women and should not invoke any custom, tradition or religious consideration to avoid their obligations with respect to its elimination. States should pursue by all appropriate means and without delay a policy of eliminating violence against women x x x. Article 68. - The husband and wife are obliged to live together, observe mutual love, respect and fidelity, and render mutual help and support. (Emphasis ours) 122 123 See Tsai v. CA, 334 Phil. 294, 304 (1997). 124 Id. at 304. Refusal to have sexual intercourse must be rooted on psychological incapacity which in turn must be established by the requirements of gravity, juridical antecedence and incurability; Baccay v. Baccay, G.R. No. 173138, December 1, 2010, 636 SCRA 350, 368369; See also the Concurring Opinion of Associate Justice Arturo D. Brion in the case stating that: "The failure to consummate the marriage by itself, however, does not constitute as a ground to nullify the marriage. The spouse's refusal to have intimate sexual relations must be due to causes psychological in nature, i.e., the psychological condition of the spouse renders [her] incapable of having intimate sexual relations with the other. x x x." 636 SCRA 350, 375. 125

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