Antonio vs Reyes

GR 155800, March 10, 2006

Tinga, J. :

Facts:

Leonilo Antonio, 26 years old, and Marie Ivonne F. Reyes, 36 years old, met each other in August
1989, barely a year after their first meeting, they got married on December 6, 1990, and a child was
born from their union, on April 19, 1991, who sadly died five months later.

On March 8, 1993, Leonilo petitioned to have his marriage declared null and void; He alleged
that Marie was psychologically incapacitated to comply with the essential marital obligations of
marriage and asserted that it existed at the time of the celebration of their marriage, up until present
day.

Leonilo’s claim that the manifestations of Marie’s psychological incapacity is that she
persistently lied about herself, the people around her, her occupation, income, educational attainment,
etc.; and that she also exhibited insecurities and jealousy towards him to the point where she would
inquire to monitor his whereabouts.

To support his petition, Leonilo presented Dr. Abcede, a psychiatrist; along with Dr. Arnulfo V.;
Dr. Lopez, a clinical psychologist, stated that, based on the test they’ve conducted, that Leonilo was
essentially normal; on the other hand Marie persistent and constant lying to Leonilo was abnormal and
pathological.

In the opposing petition, Marie claims that she performed her marital obligations, and attended
to all of the needs of her husband, and that she did not fabricate any detail that she told Leonilo; she
presented her own psychiatrist, Dr. Reyes, to refute the allegation of her psychological condition.

In rebuttal, Dr Lopez declared that there were flaws to the test and in the evaluation conducted
by Dr. Reyes, and after the trial, the lower court gave credibility Leonilo’s evidence and held that Marie’s
compulsive lying made her psychologically incapacitated as it rendered her incapable of giving any
meaning or significance to her marriage, thus, declaring their marriage null and void.

The court of appeals reversed the RTC’s decision on the ground that the evidence presented was
insufficient.

Hence this petition for review, certiorari.

Issues:

1. (CIVIL) Whether or not Leonilo has presented sufficient evidence to prove Marie’s psychological
incapacity?
Ruling:

1. Yes. Leonilo has sufficiently presented evidence and has satisfied the guidelines in Molina. 1) Apart
from his own testimony he presented witnesses, and also presented two expert witnesses in the field of
psychology who testified of Marie’s aberrant behavior and that it was tantamount to psychological
incapacity; 2) the root cause of the Marie’s psychological incapacity has been medically identified; 3) the
psychological incapacity was established to have clearly existed at the time of the celebration of the
marriage; 4 & 5) the gravity of the psychological incapacity is sufficient to prove her disability to assume
the essential marital obligations of marriage; 6) the marriage was annulled by the catholic church; 7)
Leonilo left Marie and separated from her, and then he returned wanting to make the marriage work,
but found that the Marie’s psychosis was still grave and incurable.

Disposition:

In its decision dated March 10, 2006 the courts grant the petition, and the decision rendered by the RTC
dated August 10, 1995 is reinstated.