Antonio vs Reyes

484 SCRA 353

March 10, 2006


FACTS:

Leonilo Antonio, herein petitioner, and Marie Yvonne Reyes, herein respondent, got married
primarily at Manila City Hall and subsequently in church on December 8, 1990.
Their union bore a child on April 1991, but said child died 5 months later.
It was during the duration of their first year of marriage that Antonio began noticing the
respondents habitual lying and fabrication of stories and personalities as well as issues with
jealousy that bordered on paranoia, it was also only during this time the petitioner gained
knowledge of the respondents child with another man prior to their relationship.
Petitioner and respondent separated on August 1991 for the former could not anymore tolerate
the latters behavior. He did attempt reconciliation but seeing as respondents behavior had not
improved at all even after the separation months before, he finally left her for good in November
1991.
He then filed a petition in 1993 to have his marriage with respondent declared null and void under
Article 36 of the Family Code (psychological incapacity). The trial court gave credence to
petitioner's evidence and thus declared the marriage null and void.
Court of Appeals then reversed the trial court's decision on the ground that the totality of evidence
presented was insufficient to establish respondents psychological incapacity. It declared that the
requirements in the 1997 Molina case had not been satisfied.

ISSUE:

Whether petitioner has established his cause of action for declaration of nullity of marriage under Article
36 of the Family Code and, generally, under the Molina guidelines

RULING:

YES. The petitioner, aside from his own testimony, presented his own line of witnesses and
certifications from companies that disputed his spouses claims as to her career and background.
He also presented a psychiatrist and clinical psychologist who testified as expert witnesses based
on the information petitioner had shared regarding the respondents behavior. They declared that
the persistent lying and excessive jealous behavior of the respondent is abnormal or pathological.
Furthermore, they stated that respondents fantastic ability to invent and fabricate stories and
personalities enabled her to live in a world of make- believe thus corroborating petitioners
contentions on respondent's psychological incapacity to give meaning and significance to her
marriage. Expert witnesses also attested to the fact that such behavior would render respondent
unable to commit to the basic tenets of a relationship between spouses based on love, trust, and
respect------ being an inveterate pathological liar. These alone already show that the petitioner did
indeed exhaust all efforts to present the due and necessary evidence for his cause of action and
that the psychological incapacity had been medically or clinically identified. Both of which already
satisfy two of the Molina guidelines.
Another significant requisite for the invocation of Article 36 of the family code and in accordance
with the Molina guidelines is that the alleged psychological incapacity must be existing on the
time of the celebration of the marriage, which was indeed proven in court as respondent had also
been sending letters to herself from fictitious beings that were products of her imagination even
before the marriage.
As to gravity, the period of time that the petitioner could withstand his spouses antics which was
relatively short (around 8 months), is already testament to the gravity of the psychological
incapacity, being that the parties separated not even a year into the marriage because of
respondents behavior.
The incurability of said psychological incapacity was evident during the reconciliation period as
petitioner testified that respondent had not improved at all since the separation, leading petitioner
to leave her for good.
Upon the satisfaction of the requisites and circumstances under Article 36 of the Family Code as
well as the guidelines established in the Molina Case, the SC rendered a decision granting the
petition and reinstating the decision by the RTC declaring the marriage between spouses Antonio
and Reyes null and void.