Case Digest (G.R. No. 155800)
Facts:
Leonilo Antonio v. Marie Ivonne F. Reyes, G.R. No. 155800, March 10, 2006, Supreme Court Third Division, Tinga, J., writing for the Court. Petitioner Leonilo N. Antonio sought judicial declaration that his marriage to respondent Marie Ivonne F. Reyes was void ab initio for psychological incapacity under Article 36 of the Family Code.The parties met in August 1989; they were married civilly and canonically on December 6, 1990; they had a child born April 19, 1991 who died five months later. On March 8, 1993 petitioner filed a petition for declaration of nullity under Article 36 alleging that respondent was psychologically incapacitated to comply with the essential marital obligations at the time of celebration and thereafter.
Petitioner alleged a pervasive pattern of deception by respondent: concealment of a natural son, fabrication of an attempted rape/killing by a relative, false claims of psychiatric training and singing engagements (including forged invitations and letters purportedly from third parties), altered payslips and fabricated social standing, pathological jealousy (including calling petitioner’s officemates), and extravagant spending supported by deception. Petitioner presented two experts—Dr. Dante Herrera Abcede (psychiatrist) and Dr. Arnulfo V. Lopez (clinical psychologist)—who, based on documentary evidence and records, opined that respondent’s persistent lying and paranoid jealousy were pathological and amounted to psychological incapacity. Respondent denied most allegations, offered contrary explanations, and produced Dr. Antonio Efren Reyes, who concluded from tests and screening that she was not psychologically incapacitated.
The Regional Trial Court (RTC) of Makati accepted petitioner’s evidence, credited the experts’ testimony, found respondent’s habitual fabrications and paranoia to be pathological and disabling, and on August 10, 1995 declared the marriage null and void under Article 36. During the trial period the Metropolitan Tribunal of the Archdiocese of Manila also annulled the parties’ Catholic marriage for lack of due discretion; that ruling was affirmed by the National Appellate Matrimonial Tribunal and later by the Roman Rota.
The Court of Appeals, however, reversed the RTC in a Decision dated November 29, 2001 (and by Resolution of October 24, 2002), holding that while respondent may have been dishonest, the tota...(Pro-only)
Issues:
- Did the Court of Appeals err in substituting its judgment for the RTC’s factual findings and in reversing the RTC’s declaration of nullity?
- Was respondent psychologically incapacitated to comply with the essential marital obligations under Article 36 of the Family Code such that the marriage was void ab initio?
- Must the Molina requirement that psychological incapacity be shown to be medically or clinically permanent/incurable be rigid...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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