Antonio vs.

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;

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.