Antonio vs.

Reyes
G.R. no. 155800 March 10, 2006
Tinga, J.:
Facts:
Petitioner Leonillo Antonio is asking for a petition for review on certoriari since the
C.A. reversed the RTC judgment to annul his marriage from Marie Reyes, the
respondent. The two were married on Dec. 6, 1990 and had a child that died after 5
months. Petitioner left her for good on Nov 1991 and on Mar. 8, 1993, Antonio filed
petition to to have their marriage declared null hinged on Art. 36 of the Family Code on grounds
RTC for that:
annulment Respondent is psychologically incapacitated to comply with the essential
March 8, 1993 obligations of marriage.
Respondent lied about herself (she hid her illegitimate son, made stories
about being in the commercial industry), her occupation (she lied about
being a psychiatrist), income (she manipulated her payslip, studies (she lied
about having a degree in psych), and events (she lied about her uncle
harassing her) and overly jealous (contacting petitioners co-workers for his
whereabouts).
To support his petition, Antonio presented the findings of two doctors, Dr. Abcede
and Dr. Lopez, that Reyes lying and extreme jealousy were abnormal bordering
paranoia, undermining the relationship and therefore unable to perform marital
duties. The respondent answered by claiming that she was in fact telling the truth
and even brought her own psychiatrist, Dr. Reyes, to prove that she was not
psychologically incapacitated. Dr. Lopez rebutted these by saying that the test was
not reliable and that Dr. Reyes did not conduct the tests himself. The RTC ruled in
favor of Antonio and declared their marriage void. After the decision, the
Metropolitan Tribunal of the Archdiocese of Manila annulled their Catholic marriage
on lack of due discretion on both parties, and was later on affirmed by the National
Appellate Matrimonial Tribunal but with a modification that only one of them had
lack of due discretion. This decision was also upheld by the Roman Rota of the
Vatican. Despite of these, the C.A. still reversed the decision of the RTC on grounds
that there is lack of evidence to establish psychological incapacity and Dr. Abcede did
not testify that she is incurable.
Petitioner took the case to the Supreme Court.

Issue:
Whether or not the C.A. was correct in reversing the judgment of the RTC that renders Leonilo
Antonio and Marie Reyes marriage null and void.
Secondary: whether the understanding of psychological incapacity fits the definition in Art. 36 of the
Family Code
Initially under Justices Sempio-Dy and Caguioa, psychological incapacity did not impinge on
consent, but rather people gave free and willing consent but could not comply.
Santos case changed this and defined psychological incapacity to be one where a person is
truly incognitive of the obligations of marriage
Molina case further affirms the Santos case definition. Psych incapacity must be SO GRAVE
that the spouse must not be aware of the responsibilities of marriage
The judge calls for a re-reading of this understanding since the Family Code was deigned to allow a
case-to-case basis, guided by experience, so as not to limit its application. Republic vs. Dagdag further
affirms this. The facts of the case must be examined, not a priori assumptions and generalizations.
Even the ambiguity of Molina allows for this. There are also other perspectives used in declaring
nullity:
Citing of Canon law (both in Santos and Molina) since the family code concept of psych
incapacity was derived from this, from a history of church annulment in the absence of civil
annulment.
Citing of Article XV of the Constitution sec. 1 & 2 highlighting the importance of family to deny
such annulments. This need not to be the only consideration for nullity.
It is still the legislature who decides on the definitions of legal aspects of marriage and the
strategies to protect it, given that these are in line with Constitution and Bill of Rights.
Art. 36 of the Family Code in allowing nullity of the marriage of psych incapacitated person
adheres to the constitutions protection of marriage. State must be against ill-equipped
marriages.
It must be noted that Molina was promulgated in 1997, and the events of this case happened in 1995.
The requirement of medical incurability only happened in 1997, and was not stated in the original
Family Code. Molina can be applied to past cases, since it would prejudice the cases that would not
foresee the need for proof of incurability.

Ruling:
The decision of the C.A. is reversed, the RTC ruling is updeld. For these reasons:
The state of facts presented by petitioners meets the standards for declaration of nullity
under Art 36 of the Family Code, laid down in Molina Case (even as the CA used Molina to
reverse RTC ruling)
1. Burden of proof is on the plaintiff- plaintiff provided testimony and witnesses that
supported his allegations and gave credible evidence
2. Root cause must be medically identified, alleged in complaint, and clearly explained in
decision; it must be psychological- The root cause was identified medically and clinically, it
was alleged, and proven by experts (Dr. Abcede and Dr. Lopez) who testified that she is
incapable of love, trust, respect, the foundations of marriage.
3. Incapacity must be existing at the time of celeb of marriage and I dos- Respondent has
been fabricating stories since before marriage, as well as hiding her son.
4. Incapacity must be medically incurable- the responded was already given a second chance
by petitioner yet she did not change. From the evidence, a cure would be an incredible feat
already.
5. Illness must be grave enough such that the party cannot assume the obligations of
marriage- Art 68 of the Family code says that marriage must have love, respect and
fidelityall of which a pathological liar cannot give. the lies indicate that the respondent
cannot tell truth from fiction what more a marital bond and parenting; the gravity of her
psych incapacity is seen as the marriage only lasted a little over a year. Her efforts to stay
in marriage do not remove her lack of capacity.
6. Marital obligations must be those in Art 68-71 of Family Code (for husbands and wives)
and Art 220, 221, 221 of the same code (for parents and children)
7. National Appellate Matrimonial Tribunal of the Catholic Church in the Philippines must be
respected by courts. C.A. committed an error in failing to recognize the annulment by
the Catholic Church, this is against Molina that says the NAMTCCP should be given
 respect. However, since the Catholic Church relies on the RTC, If the RTC makes a mistake,
the churchs ruling would have less value compared to the factual findings.
8. *solicitor general must issue a certification stating his reasons for agreement or
opposition (this was scrapped eventually) and appearance of the prosecuting
attorney/fiscal to ensure that there is no collusion- there is no collusion proven by the fact
that the respondent rejects the annulment, and even if they did collude, the psychological
incapacity of the spouse would negate it.
The SC gives weight to the factual findings of the RTC deemed binding to this court.