Case Digest (G.R. No. 155800)
Facts:
The case involves Leonilo Antonio as the petitioner and Marie Ivonne F. Reyes as the respondent. The events leading to the case began in August 1989 when the two met; Leonilo was 26 years old, while Marie was 36. They married on December 6, 1990, at the Manila City Hall, followed by a church wedding at Sta. Rosa de Lima Parish in Pasig, Metro Manila. They had a child born on April 19, 1991, who tragically passed away five months later. On March 8, 1993, Leonilo filed a petition in the Regional Trial Court (RTC) of Makati, seeking to have their marriage declared null and void based on Article 36 of the Family Code, claiming that Marie was psychologically incapacitated to fulfill the essential obligations of marriage.
Leonilo alleged that Marie had a history of deceit, including concealing the fact that she had previously given birth to an illegitimate child, fabricating stories about her family, misrepresenting her educational background and occupation, and exhibiting extre...
Case Digest (G.R. No. 155800)
Facts:
1. Background of the Parties
- Petitioner Leonilo Antonio and respondent Marie Ivonne F. Reyes met in August 1989. Petitioner was 26 years old, while respondent was 36.
- They married twice: first, before a minister at Manila City Hall, and later in a church wedding at Sta. Rosa de Lima Parish, Pasig, on December 6, 1990.
- They had a child who was born on April 19, 1991, but the child died five months later.
2. Allegations of Psychological Incapacity
- On March 8, 1993, petitioner filed a petition to declare the marriage null and void under Article 36 of the Family Code, alleging that respondent was psychologically incapacitated to fulfill marital obligations.
- Petitioner claimed that respondent’s incapacity existed at the time of marriage and persisted thereafter.
3. Specific Claims of Deception
- Respondent concealed that she had an illegitimate son, introducing him as an adopted child.
- She fabricated a story that her brother-in-law attempted to rape and kill her.
- She misrepresented herself as a psychiatrist and claimed to have a degree in psychology.
- She falsely claimed to be a singer affiliated with Blackgold Recording Company and fabricated a luncheon show in her honor.
- She invented friends (Babes Santos and Via Marquez) and sent letters to petitioner under their names, praising herself.
- She misrepresented her income and spent lavishly, leading to financial difficulties.
- She exhibited extreme jealousy, monitoring petitioner’s whereabouts and causing their separation in 1991.
4. Expert Testimony
- Petitioner presented Dr. Dante Herrera Abcede (psychiatrist) and Dr. Arnulfo V. Lopez (clinical psychologist), who concluded that respondent’s persistent lying and pathological jealousy rendered her psychologically incapacitated to fulfill marital obligations.
5. Respondent’s Defense
- Respondent denied most allegations, claiming she concealed her child out of fear of losing petitioner.
- She admitted to some misrepresentations but argued they were not pathological.
- She presented Dr. Antonio Efren Reyes, who testified that she was not psychologically incapacitated.
6. Lower Court Rulings
- The Regional Trial Court (RTC) declared the marriage null and void, citing respondent’s pathological lying and inability to fulfill marital obligations.
- The Court of Appeals reversed the RTC, holding that the evidence did not meet the standards for psychological incapacity under Article 36.
7. Catholic Church Tribunals
- The Metropolitan Tribunal of the Archdiocese of Manila annulled the Catholic marriage, citing lack of due discretion. This decision was affirmed by the National Appellate Matrimonial Tribunal and the Roman Rota of the Vatican.
Issue:
- Whether the Court of Appeals erred in reversing the RTC’s decision declaring the marriage null and void under Article 36 of the Family Code.
- Whether respondent’s psychological incapacity was sufficiently proven to warrant the nullity of the marriage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court reinstated the RTC’s decision, declaring the marriage null and void under Article 36 of the Family Code. The Court found that respondent’s psychological incapacity, evidenced by her pathological lying and jealousy, rendered her incapable of fulfilling the essential obligations of marriage.