Case Summary (G.R. No. 155800)
Petition and legal basis
Petitioner sought nullity under Article 36 of the Family Code alleging that respondent was psychologically incapacitated to comply with essential marital obligations, that such incapacity existed at the time of marriage and continued thereafter, and that this incapacity made the marriage void ab initio.
Specific factual allegations of respondent’s conduct
Petitioner alleged respondent engaged in persistent, pathological deception including: concealing a prior illegitimate child (presenting him as adopted), fabricating a rape/attempted murder by a relative, misrepresenting educational and professional credentials (claiming to be a psychiatrist and a recording artist), manufacturing fictitious friends and letters promoting her career, altering payslips and misrepresenting socioeconomic status, spending extravagantly and borrowing under false pretenses, and exhibiting extreme, monitoring jealousy (calling petitioner’s officemates). These behaviors were presented as chronic and pervasive.
Expert testimony and petitioner’s supporting evidence
Petitioner presented two experts — a psychiatrist (Dr. Dante Abcede) and a clinical psychologist (Dr. Arnulfo Lopez) — who, based on tests and the documentary/ testimonial record, characterized respondent as a pathological liar with paranoid jealousy and concluded these traits undermined the basic marital relationship and amounted to psychological incapacity. Corroborating evidence included witness testimony and certifications from entities (e.g., Blackgold Records, Philippine Village Hotel) contradicting respondent’s professional and social claims.
Respondent’s defense and expert evidence
Respondent denied the allegations in material respects, admitted only nondisclosure of a child out of fear of losing petitioner, and presented her own psychiatrist (Dr. Antonio Efren Reyes) who, using screening instruments including the CPRS, concluded respondent was not psychologically incapacitated. Respondent also explained or countered the specific factual allegations (e.g., professional background, luncheon event, identity of purported correspondents) and denied pathological motivations for her behavior.
Trial court findings and resolution
The RTC credited petitioner’s version, accepted the characterization of respondent’s conduct as persistent, pathological lying and paranoid jealousy, and found these traits rendered respondent incapable of giving meaning and significance to marriage and of fulfilling essential marital obligations. The RTC declared the marriage null and void under Article 36.
Canonical proceedings and their findings
Before the civil trial court decision, the Metropolitan Tribunal of the Archdiocese of Manila annulled the parties’ Catholic marriage for lack of due discretion, the NAT modified and affirmed that lack of due discretion applied to respondent (not petitioner), and the Roman Rota upheld the NAT’s conclusion. The NAT attached a restrictive clause preventing respondent from remarrying without the Tribunal’s consent, indicating a finding of serious incapacity.
Court of Appeals’ reversal
On appeal the Court of Appeals reversed the RTC, acknowledging respondent’s partial dishonesty but concluding the totality of evidence failed to meet the standards for psychological incapacity under the Molina test. The CA did not accord decisive weight to the canonical annulments and found insufficiency in proving the legal elements required for Article 36 relief.
Legal standards under Article 36 and Molina guidelines
The Court restated Molina’s guidelines applicable to Article 36 petitions: plaintiff’s burden of proof; the root cause must be psychologically/clinically identified, alleged, proven by experts, and explained in decision; the incapacity must have existed at the time of celebration; it must be medically/clinically permanent or incurable (at least as to the other spouse); it must be grave enough to disable the party from assuming essential marital obligations (not mere character quirks or occasional lapses); the noncompliance must concern obligations under Articles 68–71 and parental duties; and canonical tribunal interpretations are highly persuasive though not binding.
Credibility assessment and deference to RTC findings
The Supreme Court emphasized the trial court’s primary-trier-of-facts role and the special deference afforded to its credibility determinations, noting the CA did not dispute the veracity of petitioner’s factual evidence but simply found it insufficient under Molina. Given the RTC’s acceptance of petitioner’s factual version and the corroborating material, the Court treated those facts as operative.
Application of Molina criteria to the record
Applying Molina, the Court found: (1) petitioner carried the preponderant burden with corroborated testimony, documentary certifications, and psychological expert opinions; (2) the alleged root cause — persistent pathological lying and paranoid jealousy — was clinically identified by petitioner’s experts and
...continue readingCase Syllabus (G.R. No. 155800)
Procedural History
- Petition for Review on Certiorari filed assailing the Decision and Resolution of the Court of Appeals dated 29 November 2001 and 24 October 2002 which had reversed the judgment of the Regional Trial Court (RTC) of Makati.
- RTC of Makati originally declared the marriage of Leonilo N. Antonio (petitioner) and Marie Ivonne F. Reyes (respondent) null and void under Article 36 of the Family Code.
- Petitioner elevated the matter to the Supreme Court after the Court of Appeals reversed the RTC.
- The Supreme Court, after review, reversed the Court of Appeals and reinstated the RTC decision declaring the marriage NULL and VOID under Article 36 of the Family Code. No costs were imposed.
- Decision authored by Justice Tinga; Justices Quisumbing (Chairman), Carpio, and Carpio Morales concurred.
Antecedent Facts
- Parties met in August 1989; petitioner was 26 years old and respondent was 36.
- Civil marriage before a minister at Manila City Hall and subsequent church wedding at Sta. Rosa de Lima Parish, Bagong Ilog, Pasig on 6 December 1990.
- A child was born on 19 April 1991 who died five months later.
- Petitioner filed for declaration of nullity on 8 March 1993, alleging psychological incapacity of respondent under Article 36 of the Family Code.
- Petitioner alleged respondent’s psychological incapacity existed at the time of marriage and persisted thereafter, prompting the action.
Petition and Ground (Article 36 Claim)
- Ground: Psychological incapacity to comply with the essential obligations of marriage (Article 36, Family Code).
- Allegation that respondent’s psychological incapacity was manifest in persistent, pathological lying and extreme jealousy, undermining marital trust and duties.
- Petitioner asserted incapacity existed at time of celebration of marriage and continued up to filing.
Allegations of Petitioner — Manifestations of Psychological Incapacity
- Respondent persistently lied about personal background, relationships, occupation, income, education and other events.
- Specific alleged falsehoods and fabrications included:
- Concealment that she had previously given birth to an illegitimate son (named Tito F. Reyes II, born 21 January 1982); she introduced the boy as an adopted child and only confessed after petitioner learned truth from other sources.
- Fabrication that her brother-in-law Edwin David attempted to rape and kill her, which petitioner contended never occurred.
- Misrepresentation to her obstetrician, Dr. Consuelo Gardiner, and friends that she was a psychiatrist and a psychology graduate when she was not.
- Claims to be a singer/free-lance voice talent affiliated with Blackgold Recording Company, presentation of an invitation to a luncheon show at the Philippine Village Hotel held in her honor—certification from the hotel’s Director of Sales indicated no such event took place.
- Invention of friends “Babes Santos” and “Via Marquez,” who allegedly sent letters praising her as a top moneymaker; petitioner later learned respondent admitted she authored those letters and that such persons were not connected with Blackgold.
- Misrepresentation of financial means: alteration of payslip to appear to earn more, claiming purchased furniture came from a famous dealer when bought at a public market, lavish spending and borrowing money on false pretexts.
- Exhibited extreme jealousy and insecurity, including calling petitioner’s officemates to monitor his whereabouts; marital cohabitation effectively ended with separation in August 1991 and final departure in November 1991 after failed reconciliation attempts.
Evidence Presented by Petitioner
- Lay witnesses corroborating petitioner’s allegations and behavior described in his affidavits and testimony.
- Certifications from Blackgold Records and from the Philippine Village Hotel Pavillon disputing respondent’s singing career claims and the alleged luncheon.
- Two expert witnesses:
- Dr. Dante Herrera Abcede (psychiatrist): based on tests and assessment of petition records, described respondent’s persistent lying as abnormal/pathological; characterized extreme jealousy as paranoid and pathological; concluded respondent was psychologically incapacitated to perform essential marital obligations.
- Dr. Arnulfo V. Lopez (clinical psychologist): concluded respondent was a pathological liar and fabricated about herself; also testified on petitioner’s normal psychological profile (introspective, shy, conservative).
- Trial court credited petitioner’s evidence and factual version of events.
Respondent’s Defense and Version
- Denied most allegations of fabrication, contended she performed marital obligations and attended to petitioner’s needs.
- Specific responses to petitioner’s allegations included:
- Concealment of her earlier child was due to fear of losing petitioner.
- Story about Edwin David’s attempt to rape/kill was based on respondent’s surmise from physical touching and ogling (interpreted as intent).
- Claimed educational credentials: a BS Banking and Finance graduate; claimed to have taught psychology at Pasig Catholic School for two years.
- Claimed to be a freelance voice talent under Aris de las Alas and to have done three commercials for McCann Erickson for Coca-Cola, Johnson & Johnson, and Traders Royal Bank; asserted she reported to Blackgold offices after hours though not under contract; maintained a luncheon show at Philippine Village Hotel was held in her honor on 8 December 1979.
- Denied authorship of letters and existence of fictitious correspondents; identified Bea Marquez Recto and Babes Santos as real persons with specified whereabouts/employment.
- Admitted calling an officemate of petitioner but said the inquiry concerned a diplomatic question about chocolates, not monitoring.
- Denied lavish spending, claimed support of almost ten persons on a monthly budget of P7,000.00.
- Presented expert evidence to refute psychological incapacity claim.
Evidence Presented by Respondent
- Witness testimony and respondent’s own explanations for alleged falsehoods and behavior.
- Dr. Antonio Efren Reyes (psychiatrist):
- Conducted tests (with assistant Miss Francianina Sanches), screening procedures and the Comprehensive Psycho-Pathological Rating Scale (CPRS).
- Concluded respondent was not psychologically incapacitated to perform essential marital obligations; did not elicit regressive behavior, gross neuroticism, psychotic tendencies or poor impulse control.
- Respondent argued most of petitioner’s allegations were hearsay and unconvincing.
Expert Testimony Credibility Issues and Rebuttal
- Petitioner’s experts (Dr. Abcede and Dr. Lopez) based conclusions largely on case records and trial t