Espinosa v. Omana Digest

Antonio v.
Reyes
G.R. No. 155800, March 10, 2006 
Tinga, J. / kmd
SUBJECT MATTER: Void marriages; psychological incapacity
CASE SUMMARY: In this case, the petitioner filed a petition for the declaration of nullity of marriage.
Petitioner alleged that respondent was psychologically incapacitated as she persistently lied about herself,
the people around her, her occupation, income, educational attainment and other events or things. The SC
applied the Molina doctrine and concluded that the facts presented by petitioner sufficiently meet the
standards set for the declaration of nullity of a marriage under Article 36 of the Family Code.
DOCTRINES:
The root causes of psychological incapacity has been medically or clinically identified and proven by
experts as perennially telling lies, fabricating ridiculous stories and inventing personalities and situations,
of writing letters to petitioner using fictitious names, and of lying about her actual occupation, income,
educational attainment and family background, among others.
A person unable to distinguish between fantasy and reality would similarly be unable to comprehend the
legal nature of the marital bond, much less its psychic meaning, and the corresponding obligations
attached to marriage, including parenting.
The psychological incapacity must be shown to be medically or clinically permanent or incurable.
The requirement that psychological incapacity must be shown to be medically or clinically permanent
or incurable is one that necessarily cannot be divined without expert opinion
FACTS:
 This Petition for Review on Certiorari assails the Decision and Resolution of the CA that reversed
Makati RTC declaring the marriage of Leonilo N. Antonio (petitioner) and Marie Ivonne F.
Reyes (respondent) null and void.
 A year after their first meeting in 1989, they got married before a minister of the Gospel at the
Manila City Hall, followed by a church wedding at the Sta. Rosa de Lima Parish in Pasig on 6
December 1990.
 On 8 March 1993, petitioner filed a petition for the declaration of their marriage as null and void
under Article 36 of the Family Code alleging that respondent was psychologically incapacitated
as the respondent persistently lied about herself, the people around her, her occupation, income,
educational attainment and other events or things.
o She concealed the fact that she previously gave birth to an illegitimate son,
o fabricated a story that her brother-in-law attempted to rape and kill her,
o claimed to be a singer or a free-lance voice talent,
o invented friends,
o represented herself as a person of greater means,
o exhibited insecurities and jealousies over him to the extent of calling up his officemates
to monitor his whereabouts.
 Petitioner presented 2 clinical experts (Dr. Abcede-psychiatrist and Dr. Lopez-clinical
psychologist) who found that respondent’s persistent and constant lying and jealousy was
abnormal or pathological, undermining the couple’s basic relationship. They concluded that
respondent was psychologically incapacitated to perform essential marital obligations.
Respondent argued that the allegations were not true. Apart from her non-disclosure of a child
prior to their marriage due to fear of losing his husband, the other lies attributed to her were
hearsay and unconvincing.
 Respondent presented Dr. Reyes, a psychiatrist. Using a Comprehensive Psycho-Pathological
Rating Scale (CPRS) he himself conducted, he concluded that respondent was not
psychologically incapacitated.
 RTC declared the marriage between petitioner and respondent null and void.
 Shortly after RTC rendered its decision, the Metropolitan Tribunal of the Archdiocese of Manila
annulled the Catholic marriage of the parties, on the ground of lack of due discretion on the part
of the parties, which was affirmed with modification by both the National Appellate Matrimonial
Tribunal and Roman Rota of the Vatican.
 Appellate court reversed the RTC’s judgment as evidence presented was insufficient establish
respondent’s psychological incapacity.
N.B.
 Conclusions of the trial court regarding the credibility of witnesses are entitled to great respect.
 CA did not dispute the veracity of the evidence.
ISSUE:
WON the state of facts as presented by petitioner sufficiently meet the standards set for the declaration of
nullity of a marriage under Article 36 of the Family Code. (YES)
HOLDING:
Yes, facts presented by petitioner sufficiently meet the standards set for the declaration of nullity of a
marriage under Article 36 of the Family Code.
The court applied the Molina Guidelines to this case.
a.) Petitioner had sufficiently overcome his burden in proving the psychological incapacity of his spouse
by presenting witnesses who corroborated his allegations on his wife’s behavior, the certifications from
Blackgold Records and the Philippine Village Hotel Pavillon which disputed respondent’s claims
pertinent to her alleged singing career, and 2 expert witnesses from the field of psychology
b.) The root cause of respondent’s psychological incapacity has been medically or clinically identified
and sufficiently proven by experts. As clearly explained in the trial court’s decision, respondent is a
pathological liar, that she continues to lie, and she loves to fabricate stories about herself.
c.) Respondent’s psychological incapacity was established to have clearly existed at the time of and even
before the celebration of marriage which was established by the fact the she kept petitioner in the dark
about her natural child’s real parentage as she only confessed when the latter had found out.
d.) The gravity of respondent’s psychological incapacity is sufficient to prove her disability to assume the
essential obligations of marriage. It was noted that the couple cohabited for only a little over a year. It was
concluded that the incapacity was so grave in extent that any prolonged marital life was dubitable. Thus,
one unable to adhere to reality cannot be expected to adhere as well to any legal or emotional
commitments.
e.) The CA erred when it failed to take into consideration the fact that the Catholic Church annulled the
marriage of the parties. Such deliberate ignorance is in contravention of Molina, which held that
interpretations given by the National Appellate Matrimonial Tribunal of the Catholic Church in the
Philippines, while not controlling or decisive, should be given great respect by our courts.
f.) Psychological incapacity needs to be medically or clinically permanent or incurable. It did not appear
certain that respondent’s condition was incurable and that Dr. Abcede did not testify to such effect.
However, based on the fact that after being eparated for a month, the respondent went back to reconcile
with his wife, he realized that the behavior remained unchanged, as she continued to lie, fabricate stories,
and maintained her excessive jealousy. From this fact, he draws the conclusion that respondent’s
condition is incurable.
The SC concluded that petitioner has established his cause of action for declaration of nullity under
Article 36 of the Family Code.
Petition is GRANTED. The decision of the RTC dated 10 August 1995, declaring the marriage
between petitioner and respondent NULL and VOID under Article 36 of the Family Code, is
REINSTATED. No costs.

Espinosa v. Omana Digest

Uploaded by

Copyright:

Available Formats

Espinosa v. Omana Digest

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Espinosa v. Omana Digest

Uploaded by

Copyright:

Available Formats

Antonio v.

SUBJECT MATTER: Void marriages; psychological incapacity

The psychological incapacity must be shown to be medically or clinically permanent or incurable.

The court applied the Molina Guidelines to this case.

You might also like