Antonio vs. Reyes GR No.

155800, March 10, 2006

Facts:

In 1990, Leo married Marie, the latter being ten years his senior. In 1993, Leo filed to annul the
marriage due to Marie’s Psychological Incapacity. Leo claimed that Marie persistently lied about
herself, the people around her, her occupation, income, educational attainment and other
events or things. She would claim that she is a psychologist but she is not. She’d claim she is a
singer with the company Blackgold and that she is the latter’s number 1 money maker but she’s
not. She’d also spend lavishly as opposed to her monthly income. She fabricates things and
people only to serve her make believe world. Leo presented an expert that proved Marie’s PI.
Marie denied all Leo’s allegations and also presented an expert to prove her case. The RTC ruled
against Marie and annulled the marriage. The Matrimonial Tribunal of the church also annulled
the marriage and was affirmed by the Vatican’s Roman Rata. The CA reversed the decision hence
the appeal.

Issue:
Whether Antonio can impose Article 36 of the Family Code as basis for declaring their marriage
null and void.

Held:

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. Respondent’s 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
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 remain unchanged.