LEONILO ANTONIO, petitioner, vs. MARIE IVONNE F. REYES, respondent. TINGA, J.:

G.R. No. 155800. March 10, 2006.


On Dec 1990 Leonilo and Marie barely a year after their first meeting got married and had a child who after 5 months died. On March 1993, Leonilo filed a petition for nullity of their marriage alleging that respondent was psychologically incapacitated to comply with the essential obligations of marriage because she persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things.

This is also supported by a psychiatrist and clinical psychologist who based on the test performed that the respondents constant lying and extreme jealousy to petitioner was abnormal or pathological.

The respondent contended lies attributed to her by petitioner were mostly hearsay and unconvincing. Her stance was that the totality of the evidence presented is not sufficient for a finding of psychological incapacity on her part.

The RTC gave credit on the evidence presented by the petitioner held that respondent’s propensity to lying about almost anything—her occupation, state of health, singing abilities and her income, among others—had been duly established. According to the trial court, respondent’s 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 trial court thus declared the marriage between petitioner and respondent null and void. However the CA was not satisfied that evidence presented is sufficient to establish psychological incapacity.


Whether the state of facts as presented by petitioner sufficiently meets the standards set for the declaration of nullity of a marriage under Article 36 of the Family Code


YES. The root cause of respondent’s psychological incapacity has been medically or clinically identified, alleged in the complaint, sufficiently proven by experts, and clearly explained in the trial court’s decision. A person unable to distinguish between fantasy and reality would similarly be unable to comprehend the legal nature of the marital bond, much less its psychic meaning, and the corresponding obligations attached to marriage, including parenting.

From the totality of the evidence, we are sufficiently convinced that the incurability of respondent’s psychological incapacity has been established by the petitioner. Any lingering doubts are further dispelled by the fact that the Catholic Church tribunals, which indubitably consider incurability as an integral requisite of psychological incapacity, were sufficiently convinced that respondent was so incapacitated to contract marriage to the degree that annulment was warranted.

The notion that psychological incapacity pertains to the inability to understand the obligations of marriage, as opposed to a mere inability to comply with them, was further affirmed in the Molina case.

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