SANTOS vs. COURT OF APPEALS (1995) GR No.

112019

Petitioner: LEOUEL SANTOS Respondent: THE HONORABLE COURT OF APPEALS AND

JULIA BEDIA-SANTOS FACTS: - On September 20, 1986, Leouel Santos and Julia Rosario
Bedia-Santos exchanged vows before Judge Lazaro of the Municipal Trial Court of Iloilo City,
followed shortly thereafter, by a church wedding. - On May 1998, Julia left for the United States
to work as a nurse despite Leouel’s pleas to diss uade her. She promised him through a phone
call seven months later that she would return home but she never did. When Leouel went to the
US for a training program, he desperately tried to locate Julia but his efforts were of no avail. -
Leouel filed with the Regional Trial Court of Negros Oriental, Branch 30, a complaint for
“Voiding of Marriage Under Article 36 of the Family Code” on the ground that Julia’s failure to
return home, or at the very least to communicate with him, for more than five years are ci
rcumstances that clearly show her being psychologically incapacitated to enter into married life.
ISSUE: - W/N the wife’s failure to communicate or at least to get in touch with his husband
would constitute psychological incapacity un der Art 36 of the Family Code and would therefore
render their marriage void. HELD/RATIO: - The Court held that the facts of the case at bench do
not come close to the standards required to decree a nullity of marriage. The Court cited the
deliberations of the Family Code Revision Committee and said the use of the phrase
“psychological incapacity” under Art 36 of the Family Code has not been meant to comprehend
all such possible cases of psychoses, as likewise mentioned by some ecclesiastical authorities,
extremely low intelligence, immaturity, and like circumstances. There is hardly any doubt that
the intendment of the law has been to confine the meaning of “psychological incapacity” to the
most serious cases of personality disorders clearly demonstrative of an utter insens itivity or
inability to give meaning and significance to the marriage. Undeniably and understandably,
Leouel aggrieved, even desperate, in his present situation. Regrettably, neither law nor society
itself can always provide all the specific answers to every individual problem.

ANTONIO V. REYES Petitioner: Leonilo Antonio Respondent: Marie Ivonne Reyes

FACTS: - CA had reversed the judgment of the Makati RTC declaring the marriage of Leonilo
Antonio and Marie Ivonne Reyes, null and void. - Barely a year after their first meeting, Antonio
and Reyes got married. After almost 2 ½ years of being together, the petitioner petitioned to have