Case Digest (G.R. No. 155800) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Leonilo Antonio v. Marie Ivonne F. Reyes (G.R. No. 155800, March 10, 2006), the petitioner Leonilo N. Antonio and respondent Marie Ivonne F. Reyes met in August 1989, when he was 26 and she was 36. They solemnized their civil marriage at Manila City Hall and a subsequent church wedding at Sta. Rosa de Lima Parish, Pasig, on December 6, 1990. Their only child, born April 19, 1991, died five months later. On March 8, 1993, petitioner filed before the Regional Trial Court of Makati a petition for nullity of marriage under Article 36 of the Family Code, alleging respondent’s psychological incapacity to comply with essential marital obligations. He recounted numerous deceptions: respondent’s concealment of an illegitimate child, fabrication of a rape attempt, misrepresentation of her educational and professional credentials, false singing engagements with “Blackgold,” invented correspondents, inflated income and lavish but deceptive spending, and pathological jealousy manifesting Case Digest (G.R. No. 155800) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and marriage
- Leonilo N. Antonio (26) and Marie Ivonne F. Reyes (36) met in August 1989; married before a minister at Manila City Hall and at Sta. Rosa de Lima Parish, Pasig on December 6, 1990; had a child in April 1991 who died five months later.
- Petitioner filed a petition on March 8, 1993 under Article 36, Family Code, claiming respondent was psychologically incapacitated to comply with essential marital obligations, evidenced by persistent, pathological lying about her background, occupation, income, education, fictitious persons/events, false singing career, and extreme, paranoiac jealousy.
- Proceedings below
- Trial court (RTC Makati) accepted petitioner’s evidence: certifications from Blackgold Records and the Philippine Village Hotel, expert testimonies of Dr. Dante Herrera Abcede (psychiatrist) and Dr. Arnulfo V. Lopez (clinical psychologist) who diagnosed pathological lying and paranoia; found respondent psychologically incapacitated and declared the marriage null and void.
- Ecclesiastical annulments:
- Metropolitan Tribunal of Manila (Mar 1995) annulled the Catholic marriage for lack of due discretion on both parties.
- National Appellate Matrimonial Tribunal modified annulment, attributing lack of due discretion to respondent only.
- Roman Rota of the Vatican affirmed the National Appellate ruling.
- Court of Appeals (Nov 29, 2001) reversed the RTC, finding petitioner failed to satisfy Molina guidelines for psychological incapacity; motion for reconsideration denied Oct 24, 2002.
Issues:
- Whether respondent was psychologically incapacitated, at the time of marriage, to comply with essential marital obligations under Article 36, Family Code.
- Whether petitioner proved psychological incapacity in accordance with the Molina criteria: root cause, expert proof, timing, gravity, permanence, and breach of essential obligations.
- What persuasive weight should be accorded to the Catholic Church tribunals’ annulment decrees.
- Whether respondent’s psychological incapacity was shown to be permanent or incurable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)