G.R. No. 155800 - Antonio vs. Reyes

Case Summary (G.R. No. 155800)

Definition and Jurisprudential Evolution of Psychological Incapacity

Article 36 of the Family Code renders void from inception a marriage contracted by a party psychologically incapacitated to comply with essential marital obligations, even if incapacity manifests only after solemnization. The Supreme Court’s decision in Republic v. Court of Appeals (Molina) (1997) refined this concept: psychological incapacity must be a serious, permanent mental illness showing inability to understand and assume marital duties (Articles 68–71, 220–225). The Court drew on prior rulings (e.g., Santos v. Court of Appeals) and recognized guidance from canon law tribunals while stressing case-by-case adjudication.

Expert Testimony and Credibility Determinations

Petitioner presented Dr. Dante Herrera Abcede (psychiatrist) and Dr. Arnulfo V. Lopez (clinical psychologist). Based on affidavits, trial transcripts, and behavioral pattern, they diagnosed respondent as a pathological liar with paranoid jealousy, undermining trust and respect essential to marriage. Respondent’s expert, Dr. Antonio Efren Reyes, reported no incapacitating pathology but was critiqued for relying on a single screening instrument and not personally administering tests. The RTC gave greater credence to petitioner’s experts, finding respondent’s persistent deception pathological and rendering her incapable of fulfilling marital obligations.

Court of Appeals’ Rationale and Errors

The Court of Appeals acknowledged respondent’s dishonesty but concluded the evidence insufficient to establish psychological incapacity under Molina. It disregarded canonical annulment rulings and questioned the permanence of respondent’s condition due to the absence of unambiguous expert testimony on incurability. The Supreme Court found these errors: failure to respect binding factual findings of the RTC, disregard of persuasive weight of Catholic tribunal decisions, and misapplication of the permanence requirement in light of the case’s trial date (pre-Molina guidelines).

Application of Molina Guidelines to the Present Case

Burden of Proof (Molina 1): Petitioner established psychological incapacity by a preponderance of evidence, corroborated by witnesses, certifications, and expert opinion; there was vigorous opposition, negating collusion.
Root Cause Identification (Molina 2): The complaint alleged repeated pathological lying and jealousy; experts identified these behaviors as mental disorders and explained their impact on marital obligations.
Temporal Existence (Molina 3): Respondent’s fabrication predated and contemporaneously attended the marriage ceremony.
Permanence or Incurability (Molina 4): Although experts did not explicitly so testify—because their examinations occurred before Molina—respondent’s unremitting conduct and canonical rulings indicating permanent incapacity satisfy this requirement.
Gravity of Incapacity (Molina 5): Lies and paranoia were extreme, not mere mood swings or isolated misconduct, amounting to an adverse personality structure disabling marital consent and duties.
Essential Obligations Affected (Molina 6): Articles 68–71 obligations—mutual love, respect, fidelity, cohabitation, support, and parenta

Case Syllabus (G.R. No. 155800)

Antecedent Facts

Leonilo N. Antonio (petitioner), age 26, and Marie Ivonne F. Reyes (respondent), age 36, met in August 1989.
Civil solemnization before a minister of the Gospel at Manila City Hall, followed by a church wedding on December 6, 1990 at Sta. Rosa de Lima Parish, Pasig.
They had one child born April 19, 1991, who died five months later.
Petitioner filed a petition for declaration of nullity on March 8, 1993, invoking Article 36 of the Family Code on the ground of respondent’s alleged psychological incapacity existing at marriage celebration and persisting thereafter.

Petitioner’s Allegations of Psychological Incapacity

Respondent consistently lied about personal facts, background, education, income and other events.
She concealed her illegitimate son, presenting him as an adopted child and confessing only after petitioner discovered the truth.
She fabricated an attempted rape and murder by her brother-in-law, Edwin David, though no such incident occurred.
She misrepresented her profession as a psychiatrist and falsely claimed a degree in psychology to her obstetrician and friends.
She claimed to be a recording artist affiliated with Blackgold Recording Company, presented a fictitious luncheon invitation, and was disproved by hotel certification.
She invented fictitious friends “Babes Santos” and “Via Marquez,” wrote letters under their names praising her as a P2 million moneymaker.
She altered her payslip to inflate income, misrepresented the origin of household purchases, and incurred debts under false pretenses.
She exhibited pathological jealousy, calling petitioner’s officemates to track his whereabouts, prompting separation in August 1991 and final departure in November 1991.

Petitioner’s Evidence

Testimony of petitioner and corroborating lay witnesses documenting respondent’s fabrications and lies.
Certification from Blackgold Records and from the Director of Sales of Philippine Village Hotel negating respondent’s singing engagements and luncheon event.
Expert testimony of Dr. Dante Herrera Abcede (psychiatrist) and Dr. Arnulfo V. Lopez (clinical psychologist):
- Persistent, pathological lying undermines trust, respect and basic spousal relationship.
- Paranoid jealousy without factual basis constitutes a psychological disorder.
- Concluded respondent was incapacitated to perform essential marital obligations.

Respondent’s Opposition and Evidence

Admitted non-disclosure of her natural child but denied all other fabrications.
Claimed she was a BS Banking and Finance graduate who taught psychology for two years.
Maintained freelance voice-talent engagements with Aris de las Alas and three commercials, explaining her reporting to Blackgold offices after hours.
Asserted fictitious correspondents were real individuals with the surnames Recto and Santos, and denied authorship of lengthy letters.
Admitted a call to petitioner’s officemate was made diplomatically regarding chocolates, not to monitor him.
Denied lavish spending; said she sup