G.R. No.
155800 March 10, 2006
Leonilo
Antonio vs Marie Ivonne F. Reyes
FACTS:
Antonio
and Reyes first got married at Manila City Hall and subsequently in church on
December 8, 1990. A child was born in April 1991 but died 5 months later. Antonio could no longer take her constant
lying, insecurities and jealousies over him so he separated from her in August
1991. He attempted reconciliation but since her behavior did not change, he
finally left her for good in November 1991. Only after their marriage that he
learned about her child with another man.
He then
filed a petition in 1993 to have his marriage with Reyes declared null and void
under Article 36 of the Family Code.
The trial
court gave credence to Antonio's evidence and thus declared the marriage null
and void.
Court of
Appeals reversed the trial court's decision.
It held that the totality of evidence presented was insufficient to
establish Reyes' psychological incapacity. It declared that the requirements in
the 1997 Molina case had not been satisfied.
ISSUE:
Whether
or not Antonio has established his cause of action for declaration of nullity
under Article 36 of the Family Code and, generally, under the Molina
guidelines.
RULING:
Yes. 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.
The
factual findings of the trial court are deemed binding on the SC, owing to the
great weight accorded to the opinion of the primary trier of facts. As such, it
must be considered that respondent had consistently lied about many material
aspects as to her character and personality. Her fantastic ability to invent
and fabricate stories and personalities enabled her to live in a world of
make-believe. This made her psychologically incapacitated as it rendered her
incapable of giving meaning and significance to her marriage.
The case
sufficiently satisfies the Molina guidelines:
First,
that Antonio had sufficiently overcome his burden in proving the psychological
incapacity of his wife;
Second,
that the root cause of Reyes' psychological incapacity has been medically or
clinically identified that was sufficiently proven by experts, and was clearly
explained in the trial court's decision;
Third,
that she fabricated friends and made up letters before she married him prove
that her psychological incapacity was have existed even before the celebration
of marriage;
Fourth,
that the gravity of Reyes' 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;
Fifth,
that she being an inveterate pathological liar makes her unable to commit the
basic tenets of relationship between spouses based on love, trust, and respect.
Sixth,
that the CA clearly erred when it failed to take into consideration the fact
that the marriage was annulled by the Catholic Church. However, it is the
factual findings of the judicial trier of facts, and not of the canonical
courts, that are accorded significant recognition by this Court.
Seventh,
that Reyes' case is incurable considering that Antonio tried to reconcile with
her but her behavior remains unchanged.
