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...

Facts:

Chronology of the Parties’ Relationship

• The petitioner, Leonilo N. Antonio, and the respondent, Marie Ivonne F. Reyes, first met in August 1989 when petitioner was 26 years old and respondent was 36 years old.
• They married within a year of their initial meeting, first in a civil ceremony at the Manila City Hall and later in a church wedding at Sta. Rosa de Lima Parish, Pasig, on December 6, 1990.
• Their union produced one child, born on April 19, 1991, who unfortunately died five months later.

Allegations of Deceit and Psychological Incapacity

• Petition for Nullity Initiation
• On March 8, 1993, petitioner filed a petition to have the marriage declared null and void under Article 36 of the Family Code.
• He based his claim on respondent’s alleged psychological incapacity to comply with essential marital obligations.
• Specific Misrepresentations by Respondent
• Concealment of a previous illegitimate child by presenting the child as “adopted” and only later admitting the truth.
• Fabrication of an incident involving her brother-in-law, Edwin David, claiming he attempted to rape and kill her, although no such incident occurred.
• Misrepresentation of her professional credentials by falsely claiming to be a psychiatrist and a psychology graduate, while also presenting herself as a singer affiliated with Blackgold Recording Company with fictitious evidence of a luncheon show held in her honor.
• Invention of fictitious friends (Babes Santos and Via Marquez) and circulating letters that touted her as a “number one moneymaker” in the commercial industry, later admitted to be self-authored fabrications.
• Alteration of financial documents to exaggerate her income and misrepresentations regarding significant purchases to portray a higher standard of living.
• Exhibiting extreme jealousy by contacting petitioner’s officemates to monitor his whereabouts, contributing to the deterioration of their relationship.
• Pattern of Behavior and Its Impact
• Respondent’s persistent lying and fabrication of stories undermined trust, a core element in the marital relationship.
• This behavioral pattern was characterized as abnormal, leading petitioner to conclude that she was psychologically incapable of fulfilling marital obligations.
• The petitioner’s separation from respondent began in August 1991, with final separation occurring in November 1991 after failed reconciliation attempts.

Presentation of Evidence and Expert Testimonies

• Expert Evidence in Support of Psychological Incapacity
• Dr. Dante Herrera Abcede (psychiatrist) testified that respondent’s persistent lying was abnormal and destructive to the trust and respect essential in marriage.
• Dr. Arnulfo V. Lopez (clinical psychologist) corroborated that respondent was a pathological liar whose behavior rendered her unable to perform the basic obligations of marriage.
• Corroborative Evidence
• Documentary evidence, including certifications from Blackgold Recording Company and the Philippine Village Hotel, disputed respondent’s claims regarding her professional endeavors.
• Multiple witness testimonies supported the petitioner’s allegations by establishing a consistent pattern of deceit and abnormal behavior.

Lower Court Proceedings and External Annulment Rulings

• The Regional Trial Court (RTC) of Makati declared the marriage null and void under Article 36, giving significant credence to petitioner’s evidence and expert testimony.
• Canonical Proceedings
• The Metropolitan Tribunal of the Archdiocese of Manila annulled the Catholic marriage on the ground of lack of due discretion.
• This ruling was subsequently modified and upheld by the National Appellate Matrimonial Tribunal and the Roman Rota of the Vatican, emphasizing respondent’s incapacity.
• Appeal and Court of Appeals Reversal
• The Court of Appeals reversed the RTC’s declaration of nullity, holding that despite some dishonesty, the evidence was insufficient to conclusively establish psychological incapacity.

Procedural Posture Leading to the Supreme Court

• The petitioner elevated the case to the Supreme Court, contending that the factual findings of the RTC—especially regarding respondent’s pattern of deceit—were decisively supported by evidence.
• The Supreme Court was tasked with determining whether the totality of the evidence met the stringent requirements under Article 36 and the evolving Molina guidelines.

Issue:

Sufficiency of Evidence

• Whether the petitioner established by a preponderance of evidence that the respondent was psychologically incapacitated to comply with the essential marital obligations as required under Article 36 of the Family Code.

Application of the Molina Guidelines

• Whether the factual record satisfies the Molina guidelines concerning (a) the burden of proof, (b) the identification of a medically or clinically recognized psychological condition, (c) the existence of the incapacity at the time of the marriage, and (d) its permanence or incurability.

Credibility and Weight of Evidence

• Whether the trial court’s favorable assessment of the petitioner’s evidence and the credibility of his witnesses should command deference over the Court of Appeals’ contrary finding.

Impact of Canonical Annulment Rulings

• Whether the rulings by the Catholic Church (Metropolitan Tribunal, National Appellate Matrimonial Tribunal, and Roman Rota) concerning the nullification of the marriage should influence the civil court’s determination of psychological incapacity.

Determination of Incurability

• Whether the lack of explicit expert testimony on the incurability of the respondent’s condition undermines the petitioner’s claim or whether the overall evidence implies its permanence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)