ANTONIO V REYES

GR 15500
March 10, 2006
Potente: Tinga

FACTS:
This is a case on declaring the marriage between the petitioner and respondent null and void on
the basis of psychological incapacity of the respondent to comply with the essential obligations of
marriage.

 Petitioner and respondent who was 10 years older than the petitioner, got married before a
minister of the Gospel at the Manila City Hall, year after they first met and a church wedding at
Pasig, Metro Manila, a year later. They had a child on April 1991 but died five months later.
 Petitioner filed a petition for to have his marriage declared null & void, alleging that the
respondent was psychologically incapacitated to comply with essential obligations of marriage.
Additionally, he asserted that the incapacity existed at the time their marriage was celebrated
and still subsists up to the present.
 He further alleged that the respondent’s incapacity is exhibited in various manners such as:
persistently lying about herself, the people around her, occupation, income, educational
attainment and other events:
o Concealed the fact that she gave birth to an illegitimate child, but introduced the boy as
the adopted child of her family;
o Fabricated a story that her brother-in-law, Edwin David, attempted to rape and kill her;
o Misrepresented herself as a psychiatrist to her OB, and told some of her friends that she
graduated with a degree in Psychology;
o Claimed to be a singer or free-lance voice talent of Blackgold Recording Co; and a
luncheon in her honor was held at Philippine Village Hotel;
o Invented fictitious friends named Babes Santos and Via Marquez, who supposedly
tagged her as Blackgold’s “number one moneymaker” in a commercial worth P2 million.
o Represented herself as a person of greater means altering her payslip to make it appear
that she earned a higher income.
o Exhibited insecurities and jealousies to the extent of calling the petitioner’s officemates
to monitor his whereabouts.
 Petitioner, on one hand, presented Dr. Abcede, a psychiatrist and Dr. Lopez, a clinical
psychologist, who stated that based on the test they conducted, the petitioner was normal,
introspective, shy and conservative person. On the other hand, they observed that the
respondent was abnormal or pathological due to her persistent and constant lying, undermining
that basic relationship should be based on love, trust, and respect. Respondent’s extreme
jealousy was also pathological reaching a point of paranoia. They concluded that respondent
was psychologically incapacitated to perform essential marital obligations.
 Respondent, on the other hand, claimed that she performed her marital obligations by
attending to all needs of her husband and that there was no truth in the allegation that she
fabricated stories, told lies, and invented personalities.
 She claimed that the lies the petitioner attributed to her are mostly hearsay and unconvincing,
and the totality of the evidence presented is not sufficient for finding a psychological incapacity
on her part.
 She also presented Dr. Reyes, a psychiatrist, to refute the allegations on her psychological
condition. He testified that the series of tests conducted by his assistant, together with the
screening procedure and the Comprehensive Psycho-Pathological Rating Scale (CPRS) that he
conducted, made him conclude that the respondent was not psychologically incapacitated to
perform the essential marital obligations.
 Accordingly, the regressive behavior, gross neuroticism, psychotic tendencies, poor control of
impulses which are signs that might point to the presence of disabling trends, were not
exhibited by the respondent.
 Dr. Lopez, rebutted this claim citing that there were flaws in the evaluation conducted by Dr.
Reyes—he was not the one who administered and interpreted the respondent’s psychological
evaluation; the CPRS was not reliable because a good liar can fake the results of such test.
 The lower court give credence to petitioner’s evidence and held that the respondent’s
propensity to lying about almost anything has been established making her psychologically
incapacitated as it rendered her incapable of giving meaning and significance to her marriage,
thus declaring the marriage between the petitioner and respondent null & void.
 The Metropolitan Tribunal of the Archdiocese of Manila annulled the Catholic marriage of the
parties on the ground of lack of due discretion on the part of the parties. This was affirmed with
modification by both National Appellate Matrimonial Tribunal which held that only the
respondent was impaired by lack of due discretion. This decision was upheld by the Roman Rota
of the Vatican.
 Petitioner alerted CA of these rulings of the Catholic Tribunals, but appellate court reversed
RTC’s decision. CA held that the totality of the evidence presented was insufficient to establish
respondent’s psychological incapacity. It contested that the requirements in the case of
Republic v CA (Molina Case) governing application and interpretation of psychological incapacity
had not been satisfied.

ISSUE
WON the state of facts as presented by petitioner sufficiently meets the standards set for
declaration of nullity of marriage under Article 36 of the Family Code.

HELD:
The petition declaring the marriage between petitioner and respondent NULL and VOID under
Article 36 of the Family Code is granted.
The SC accepted the factual version of the petitioner as the operative facts of this case. They
averred that while the Molina Case and the succeeding cases set the guidelines on the petition on
declaration of nullity, it still leave room for a decree of nullity under proper circumstances that are
applicable in the case at bar. It also cited Republic v Dagdag, that annulment of marriage depends
crucially, on the facts of the case. Each case must be judged not on the basis of prior assumptions
but according to its own facts.
Furthermore, it also reiterated that in denying petitions of the kind, the courts frequently
favorably cited Sections 1 & 2, Article XV of the Constitution, whose provisions highlight the
importance of the family and the constitutional protection accorded to the institution of marriage.
However, it clarified that, the Constitution itself does not establish the parameters of state
protection as a social institution and foundation of the family. It remains the area of jurisdiction to
define all legal aspects of marriage and prescribe the strategy and the modalities to protect based
on whatever socio-political influences it deems proper. Moreover, Article 36 of the Family Code, in
classifying marriages contracted by a psychologically incapacitated person as a nullity, should be
deemed as an implement of this constitutional protection of marriage. Additionally, void ab initio
marriages under the preceding Article do not further the initiatives of the state concerning marriage
& family as they promote wedlock among persons who, for reasons independent of their will, are
not capacitated to understand or comply with the essential obligations of marriage.

Lastly, the court found no impelling cause to present evidence of an expert medical or clinical
diagnosis of incurability since the case was tried 10 years ago before the Molina and Santos cases.
From the totality of evidence presented, the court was sufficiently convinced that the incurability of
respondent’s incurability psychological incapacity has been established by the petitioner.