G.R. No. 155800, 10 March 2006
Leonilo Antonio, 26 years of age, and Marie Ivonne Reyes, 36 years of age met in 1989. Barely a year after their first meeting, they got married at Manila City Hall and then a subsequent church wedding at Pasig in December 1990. A child was born but died 5 months later. Reyes persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things. She even did not conceal bearing an illegitimate child, which she represented to her husband as adopted child of their family. They were separated in August 1991 and after attempt for reconciliation, he finally left her for good in November 1991. Petitioner then filed in 1993 a petition to have his marriage with Reyes declared null and void anchored in Article 36 of the Family Code.
Whether Antonio can impose Article 36 of the Family Code as basis for declaring their marriage null and void.
The court held that petitioner has established his cause of action for declaration of nullity under Article 36 of the Family Code.
Art. 36. A marriage contracted by any party who, at the time of the celebration, was incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization.
Psychological incapacity pertains to the inability to understand the obligations of marriage as opposed to a mere inability to comply with them. The petitioner, aside from his own testimony presented a psychiatrist and clinical psychologist who attested that constant lying and extreme jealousy of Reyes is abnormal and pathological and corroborated his allegations on his wife’s behavior, which amounts to psychological incapacity. Respondent’s fantastic ability to invent, fabricate stories and letters of fictitious characters enabled her to live in a world of make-believe that made her psychologically incapacitated as it rendered her incapable of giving meaning and significance to her marriage.
The root causes of Reyes’ psychological incapacity have been medically or clinically identified that was sufficiently proven by experts. The gravity of respondent’s psychological incapacity was considered so grave that a restrictive clause was appended to the sentence of nullity prohibited by the National Appellate Matrimonial Tribunal from contracting marriage without their consent. It would be difficult for an inveterate pathological liar to commit the basic tenets of relationship between spouses based on love, trust and respect. Furthermore, Reyes’ case is incurable considering that petitioner tried to reconcile with her but her behavior remain unchanged.
* Case digest by Aileen B. Buenafe, LLB-1, Andres Bonifacio Law School, SY 2017-2018