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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.

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