107. ANTONIO v.

REYES

GR No. 155800, March 10, 2006

Facts: Leonilo Antonio and Marie Ivonne Reyes got married barely a year after their first meeting.
A child was born but died 5 months later. Reyes persistently lied about herself, the people around
her, her occupation, income, educational attainment and other events or things. She even did not
conceal bearing an illegitimate child, which she represented to her husband as adopted child of their
family. They were separated in August 1991 and after attempt for reconciliation, he finally left her
for good in November 1991. Petitioner then filed in a petition to have his marriage with Reyes
declared null and void anchored in Article 36 of the Family Code.

Issue: Is Reyes psychologically incapcitated

Held: Yes. Psychological incapacity pertains to the inability to understand the obligations of marriage
as opposed to a mere inability to comply with them. 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 wifes
behavior, which amounts to psychological incapacity. Respondents fantastic ability to invent,
fabricate stories and letters of fictitious characters enabled her to live in a world of make-believe that
made her psychologically incapacitated as it rendered her incapable of giving meaning and
significance to her marriage. The root causes of Reyes psychological incapacity have been medically
or clinically identified that was sufficiently proven by experts. The gravity of respondents
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. It would be difficult for an inveterate pathological liar to commit the
basic tenets of relationship between spouses based on love, trust and respect. Furthermore, Reyes
case is incurable considering that petitioner tried to reconcile with her but her behavior remain
unchanged. Hence, the court conclude that petitioner has established his cause of action for
declaration of nullity under Article 36 of the Family Code.