Leonilo Antonio vs Marie Ivonne F. Reyes G.R. No.
155800 March 10, 2006 FACTS:
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 that he learned 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.
The factual findings of the trial court are deemed binding on the SC, owing to the great weight accorded
to the opinion of the primary trier of facts. As such, it must be considered that respondent had
consistently lied about many material aspects as to her character and personality. Her fantastic ability to
invent and fabricate stories and personalities enabled her to live in a world of 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;
Second, that the root cause of Reyes' psychological incapacity has been medically or clinically identified
that was sufficiently proven by experts, and was clearly explained in the trial court's decision;
Third, that she fabricated friends and made up letters before she married him prove that her
psychological incapacity was have existed even before the celebration of marriage;
Fourth, that the gravity of Reyes' psychological incapacity was considered so grave that a restrictive
clause was appended to the sentence of nullity prohibited by the National Appellate Matrimonial
Tribunal from contracting marriage without their consent;
Fifth, that she being an inveterate pathological liar makes her unable to commit the basic tenets of
relationship between spouses based on love, trust, and respect.
Sixth, that the CA clearly erred when it failed to take into consideration the fact that the marriage was
annulled by the Catholic Church. However, it is the factual findings of the judicial trier of facts, and not of
the canonical courts, that are accorded significant recognition by this Court.
Seventh, that Reyes' case is incurable considering that Antonio tried to reconcile with her but her
behavior remains unchanged.
Antonio vs. Reyes GR No. 155800, March 10, 2006
Leonilo Antonio, 26 years of age, and Marie Ivonne Reyes, 36 years of age met in
1989. Barely a year after their first meeting, they got married at Manila City Hall
and then a subsequent church wedding at Pasig in December 1990. A child was
born but died 5 months later. Reyes persistently lied about herself, the people
around her, her occupation, income, educational attainment and other events or
things. She even did not conceal bearing an illegitimate child, which she
represented to her husband as adopted child of their family. They were separated in
August 1991 and after attempt for reconciliation, he finally left her for good in
November 1991. Petitioner then filed in 1993 a petition to have his marriage with
Reyes declared null and void anchored in Article 36 of the Family Code.
ISSUE: Whether Antonio can impose Article 36 of the Family Code as basis for
declaring their marriage null and void.
HELD:
Psychological incapacity pertains to the inability to understand the obligations of
marriage as opposed to a mere inability to comply with them. 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 wifes behavior, which amounts
to psychological incapacity. Respondents fantastic ability to invent, fabricate stories
and letters of fictitious characters enabled her to live in a world of make-believe that
made her psychologically incapacitated as it rendered her incapable of giving
meaning and significance to her marriage. The root causes of Reyes psychological
incapacity have been medically or clinically identified that was sufficiently proven by
experts. The gravity of respondents psychological incapacity was considered so
grave that a restrictive clause was appended to the sentence of nullity prohibited by
the National Appellate Matrimonial Tribunal from contracting marriage without their
consent. It would be difficult for an inveterate pathological liar to commit the basic
tenets of relationship between spouses based on love, trust and respect.
Furthermore, Reyes case is incurable considering that petitioner tried to reconcile
with her but her behavior remain unchanged.
Hence, the court conclude that petitioner has established his cause of action for
declaration of nullity under Article 36 of the Family Code.
Art 45 (3) distinguished from Psychological Incapacity
In 1990, Leo married Marie, the latter being ten years his senior. In 1993, Leo filed to annul the
marriage due to Maries PI. Leo claimed that Marie persistently lied about herself, the people around
her, her occupation, income, educational attainment and other events or things. She would claim that
she is a psychologist but she is not. Shed claim she is a singer with the company Blackgold and that
she is the latters number 1 money makerbut shes not. Shed also spend lavishly as opposed to her
monthly income. She fabricates things and people only to serve her make believe world. Leo
presented an expert that proved Maries PI. Marie denied all Leos allegations and also presented an
expert to prove her case. The RTC ruled against Marie and annulled the marriage. The Matrimonial
Tribunal of the church also annulled the marriage and was affirmed by the Vaticans Roman Rata. The
CA reversed the decision hence the appeal.
ISSUE: Whether or not PI is attendant to the case.
HELD: Yes, PI is attendant. The guidelines established in the Molina case is properly established in
the case at bar.
The SC also emphasized what fraud means as contemplated in Art 45 (3) of the FC vis a vis Art 46 of
the FC. In PI, the misrepresentation done by Marie points to her inadequacy to cope with her marital
obligations, kindred to psychological incapacity. In Art 45 (3), marriage may be annulled if the consent
of either party was obtained by fraud, and Article 46 which enumerates the circumstances constituting
fraud under the previous article, clarifies that no other misrepresentation or deceit as to character,
health, rank, fortune or chastity shall constitute such fraud as will give grounds for action for the
annulment of marriage. These provisions of Art 45 (3) and Art 46 cannot be applied in the case at bar
because the misrepresentations done by Marie is not considered as fraud but rather such
misrepresentations constitute her aberrant behaviour which further constitutes PI. Her
misrepresentations are not lies sought to vitiate Leos consent to marry her. Her misrepresentations are
evidence that Marie cannot simply distinguish fiction/fantasy from reality which is so grave and it falls
under the fourth guideline laid down in the Molina Case.