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Leonilo Antonio, petitioner vs. Marie Ivonne F.

Reyes, respondent
GR no. 155800 March 10, 2006

Leonilo and Marie met in August 1989 and barely a
year after they met, they got married. Out of their union, a child was born on
April 19, 1991 who died after five months.
On March 8, 1993, Leonilo filed a petition to have his marriage to Marie
declared null and void invoking Article 36 of the Family Code. He alleged that
Marie was psychologically incapacitated to comply with the essential
obligations of marriage because Marie persistently and constantly lies about
herself, the people around her, occupation, income, educational attainment,
and other events or things. Leonilo also stated that Marie is paranoid and
always jealous. Marie opposed the petition claiming that she performed her
marital obligations by attending to all the needs of her husband. She also
asserted that the allegations of his husband were not true.
The RTC gave credence to the petitioners evidence and declared the
marriage of Leonilo and Marie null and void. Before the RTC rendered its
decision, the Metropolitan Tribunal of the Archdiocese of Manila annulled the
Catholic Marriage of the parties. The National Appellate Matrimonal Tribunal
and the Roman Rota of the Vatican, affirmed and upheld the decision of the
Metropolitan Tribunal respectively.
Marie appealed to the Court of Appeals. The appellate court reversed
the decision of the RTC and held that the evidence given by Leonilo was not
sufficient enough to prove the psychological incapacity of Marie.
Whether or not Maries persistence and consistency in lying constitutes
psychological incapacity.
Yes. The case sufficiently satisfies the seven guidelines in the Molina
case. First, the petioner had sufficiently overcome his burden in proving the
psychological incapacity of Marie. Second, the root cause of the respondents
psychological incapacity has been medically or clinically identified. Third, the
psychological incapacity of the Marie was proven to be existing during the
marriage for she fabricated stories before she married the petitioner. Fourth,
the gravity of Maries incapacity was proven wherein Maries failure to
distinguish truth from fiction, or at least abide by the truth would be similarly

be unable to comprehend the legal nature of marital bonds and marital

obligations. Fifth, Marie is evidently not able to comply with the essential
marital obligations as stated in articles 68 to 71 of the family code. In which,
Article 68 enjoins the spouses to live together, observe mutual love, respect,
and fidelity, and render mutual help and support. The court states that, Marie
being a liar would not be able to commit to the basic tenets of relationship
which are love, trust, and respect. Sixth, the Court of Appeals clearly erred
when it failed to take into consideration the fact the marriage of the parties
was annulled by the Catholic Church when rulings of the Catholic Church
should be given persuasive value. Seventh, Maries psychological incapacity
was proven to be incurable in a way that when Leonilo and Marie first
separated, Leonilo returned to her desiring that they would be able to make
their marriage work however Marie still remained unchanged.