Antonio vs. Reyes

In 1990, Leonilo Antonio married Marie Ivonne Reyes, who was ten years older than Leonilo.
In 1993,
Leonilo filed a petition to annul their marriage due to the alleged psychological incapacity of Reyes.
Leonilo claimed that Marie persistently lied about herself, the people around her, her occupation,
income, educational attainment and other events or things. She would claim that she is a
psychologist but she is not. She’d claim she is a singer with the company Blackgold and that she is
the latter’s number 1 money maker but she’s not. She’d also spend lavishly as opposed to her
monthly income. She fabricates things and people only to serve her make-believe world.
Leonilo presented an expert who testified to Reyes’s psychological incapacity. Reyes denied all of
Leonilo’s allegations and she also presented an expert to prove her case. The RTC ruled against
Reyes and declared their marriage void. Meanwhile, The Matrimonial Tribunal of the church also
annulled the marriage and was even affirmed by the Vatican’s Roman Rata. However, the Court of
Appeals reversed the decision hence the appeal.
ISSUE:
Can petitioner invoke Article 36 of the Family Code as a ground for the declaration of nullity of his
marriage?
HELD: Yes, Reyes was proven to be psychologically incapacitated
The present case sufficiently satisfies the guidelines set in the Molina case. First, the petitioner had
sufficiently overcome his burden in proving the psychological incapacity of his spouse. Second, the
root cause of the respondent’s psychological incapacity has been medically identified, alleged in the
complaint, sufficiently proven by experts and clearly explained in the trial court’s decision. Third,
psychological incapacity was established to have already existed at the time of and even before the
celebration of marriage. Fourth, the gravity of respondent’s psychological incapacity is sufficient to
prove her disability to assume the essential obligations of marriage. Fifth, respondent is evidently
unable to comply with the essential marital obligations. Sixth, the Court of Appeals clearly erred
when it failed to take into consideration the fact that the marriage of the parties was annulled by the
Catholic Church. Seventh, although it was not clinically proven that the psychological incapacity is
incurable, the fact that the petitioner returned to his wife in hopes of fixing their marriage and yet
the latter’s behavior remained unchanged shows that the respondent’s condition is incurable. The
Molina case is not set in stone and that the interpretation of Article 36 relies heavily on a case-to-
case perception. As such, strict enforcement of the guidelines is not necessary thus, the petition is
granted, the ruling of the RTC affirmed and of CA reversed.
In this cases also, the Supreme Court emphasized what fraud or misrepresentation means as
contemplated in Article 45 (3) of the Family Code vis-a-vis Article 46. The misrepresentation done by
Reyes points to her inadequacy to cope with her marital obligations, kindred to psychological
incapacity. In Article 45 (3), marriage may be annulled if the consent of either party was obtained by
fraud, and Article 46 which enumerates the circumstances constituting fraud under the previous
article, clarifies that “no other misrepresentation or deceit as to character, health, rank, fortune or
chastity shall constitute such fraud as will give grounds for action for the annulment of marriage.” These
provisions of Article 45 (3) and Article 46 cannot be applied in the case at bar because the
misrepresentations done by Reyes is not considered as fraud but rather such misrepresentations
constitute her aberrant behaviour which further constitutes Psychological Incapacity. Her
misrepresentations are not lies sought to vitiate Leonilo’s consent to marry her. Her
misrepresentations are evidence that Marie cannot simply distinguish fiction/fantasy from reality
which is so grave and it falls under the fourth guideline laid down in the Molina Case.

Antonio vs. Reyes

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Antonio vs. Reyes

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In 1990, Leonilo Antonio married Marie Ivonne Reyes, who was ten years older than Leonilo.

HELD: Yes, Reyes was proven to be psychologically incapacitated

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