YASSER M.

MAMBUAY
PAFR (Atty. Turingan)
TOLENTINO V. REYES
G.R. No. 155800
March 10, 2006

FACTS:
Petitioner and respondent met in August 1989 when petitioner was 26 years old and respondent was 36
years of age. Barely a year after their first meeting, they got married before a minister of the Gospel at the Manila
City Hall, and through a subsequent church wedding at the Pasig, Metro Manila on December 6, 1990. Out of their
union, a child was born on April 19, 1991, who sadly died five (5) months later. On March 8, 1993, petitioner filed a
petition to have his marriage to respondent declared null and void. He anchored his petition for nullity on Article 36 of
the Family Code alleging that respondent was psychologically incapacitated to comply with the essential obligations
of marriage. He asserted that respondent’s incapacity existed at the time their marriage was celebrated and still
subsists up to the present. As manifestations of respondent’s alleged psychological incapacity, petitioner claimed that
respondent persistently lied about herself, the people around her, her occupation, income, educational attainment
and other events or things. Respondent exhibited insecurities and jealousies over the petitioner to the extent of
calling up the latter’s officemates to monitor his whereabouts. She even did not conceal bearing an illegitimate child,
which she represented to her husband as adopted child of their family. When the petitioner could no longer take the
respondent’s unusual behavior, he separated from her in August 1991. He tried to attempt a reconciliation but since
her behavior did not change, he finally left her for good in November 1991. 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. 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 wife's behavior, which amounts to psychological incapacity.

The factual findings of the trial court are deemed binding on the SC, owing to the great weight accorded to
the opinion of the primary trier of facts. As such, it must be considered that respondent had consistently lied about
many material aspects as to her character and personality. Her 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 root causes of Reyes’ psychological incapacity have been medically or clinically identified that was
sufficiently proven by experts. The gravity of respondent’s 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 remains unchanged.

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.

Hence, the court conclude that petitioner has established his cause of action for declaration of nullity under
Article 36 of the Family Code.