Antonio vs. Reyes, G.R. No.

155800, March 10, 2006

FACTS: Petitioner filed a pet to declare his marriage to the respondent null & void on the
ground of psychological incapacity. Petr claimed that the resp is psychologically
incapacitated to comply w/the essential obgns of marriage bec she lied about herself, the
people around her, her occupation, income, educational attainment & other events. She
exhibited insecurities & jealousies.
ISSUE: WON petr Antonio has established his cause of action to declare his marriage to the
resp null & void on the ground of psychological incapacity under the Molina guidelines.
HELD: Yes. The root cause of Reyes’ psychological incapacity have been medically or
clinically identified that was sufficiently proven by experts.
A person who is unable to distinguish bet fantasy & reality wld be unable to
comprehend the legal nature of the marital bond & the oblgn attached to the marriage
including parenting. One who is unable to adhere to reality cannot be expected to adhere to
any legal or emotional commitments.
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;
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 is 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