Antonio vs. Reyes GR No.

155800, March 10, 2006 FACTS: Leonilo Antonio filed in 1993 before the Regional Trial Court (RTC) of Makatia petition nullifying his marriage to Marie Ivonne Reyes under the grounds of psychological incapacity. The alleged facts are as follows:

1. Leonilo Antonio and Marie Ivonne Reyes got married at Manila City Hall a year after they 2. 3. 4.
met in August 1989. A child was born but died 5 months later. Reyes persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things. She concealed bearing an illegitimate child, which she represented to her husband as adopted child of their family. They were separated in August 1991 and after attempt for reconciliation, he finally left her for good in November 1991.

The RTC granted the petition. The CA reversed the RTCs decision hence, this petition. ISSUE: Whether Antonio can impose Article 36 of the Family Code as basis for declaring their marriage null and void. HELD: Yes. The SC concludes that petitioner has established his cause of action for declaration of nullity under Article 36 of the Family Code due to the following grounds:

1. Psychological incapacity pertains to the inability to understand the obligations of marriage

as opposed to a mere inability to comply with them.

2. The petitioner 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 wifes behavior, which amounts to psychological incapacity. Respondents fantastic ability to invent, fabricate stories and letters of fictitious characters enabled her to live in a world of make-believe that 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 respondents 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. Reyes case is incurable considering that petitioner tried to reconcile with her but her behavior remain unchanged.

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