Professional Documents
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Reyes
G.R. No. 155800 March 10, 2006
In relation to Art. 36 of the Family Code
FACTS:
Antonio and Reyes first got married at Manila City Hall and
subsequently in church on December 8, 1990. A child was born in April
1991 but died 5 months later. Antonio could no longer take her
constant lying, insecurities and jealousies over him so he separated
from her in August 1991. He attempted reconciliation but since her
behavior did not change, he finally left her for good in November 1991.
Only after their marriage did he learn about her child with another
man.
He then filed a petition in 1993 to have his marriage with Reyes
declared null and void under Article 36 of the Family Code.
The trial court gave credence to Antonio's evidence and thus declared
the marriage null and void.
Court of Appeals reversed the trial court's decision. It held that the
totality of evidence presented was insufficient to establish Reyes'
psychological incapacity. It declared that the requirements in the 1997
Molina case had not been satisfied.
ISSUE:
Whether or not Antonio has established his cause of action for
declaration of nullity under Article 36 of the Family Code and,
generally, under the Molina guidelines.
RULING:
Yes. The petitioner, aside from his own testimony, presented a
psychiatrist and clinical psychologist who attested that constant lying
and extreme jealousy of Reyes is abnormal and pathological and
corroborated his allegations on his wife's behavior, which amounts to
psychological incapacity.
Respondent had consistently lied about many material aspects as to
her character and personality. She lived in a make-believe. This made
her psychologically incapacitated as it rendered her incapable of giving
meaning and significance to her marriage.
The case sufficiently satisfies the Molina guidelines:
First, that Antonio had sufficiently overcome his burden in proving the
psychological incapacity of his wife;