Antonio vs Reyes G.R. No.

155800

484 SCRA 353 Civil Law Family Code Annulment of Marriage Article 45 (3)
distinguished from Psychological Incapacity (Article 36)
In 1990, Leonilo Antonio married Marie Ivonne Reyes, who was ten years older than
Leonilo. In 1993, Leo filed a petition to annul their marriage due to the alleged psychological
incapacity of Reyes. Leonilo 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 maker but shes not. Shed
also spend lavishly as opposed to her monthly income. She fabricates things and people
only to serve her make-believe world.
Leonilo presented an expert who testified to Reyess psychological incapacity.
Reyes denied all of Leonilos allegations and she also presented an expert to prove her
case. The RTC ruled against Reyes and declared their marriage void. Meanwhile, The
Matrimonial Tribunal of the church also annulled the marriage and was even affirmed by
the Vaticans Roman Rata. However, the Court of Appeals reversed the decision hence the
appeal.
ISSUE: Whether or not Marie Ivonne Reyes is psychologically incapacitated.
HELD: Yes, Reyes was proven to be psychologically incapacitated.
In this cases also, the Supreme Court emphasized what fraud or misrepresentation means
as contemplated in Article 45 (3) of the Family Code vis-a-vis Article 46. But first, it must be
stated: in Psychological Incapacity, the misrepresentation done by Reyes points to her
inadequacy to cope with her marital obligations, kindred to psychological incapacity. In
Article 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 Article 45 (3) and Article 46 cannot be applied
in the case at bar because the misrepresentations done by Reyes is not considered as

fraud but rather such misrepresentations constitute her aberrant behaviour which further
constitutes Psychological Incapacity. Her misrepresentations are not lies sought to vitiate
Leonilos 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.