6.

De Leon

Leonilo Antonio vs Marie Ivonne Reyes (G.R. No. 155800)

Facts: Leonilo Antonio and Marie Ivonne Reyes got married before a minister of the
Gospel at the Manila City Hall and subsequently got married at a church in Pasig on
December 6, 1990. In 1993, Leo filed a petition to have his marriage declare null and
void on the ground of Marie’s Psychological Incapacity. Leo claimed that Marie
persistently lied about herself, the people around her, her occupation, income,
educational attainment and other events or things. Leo presented an expert that proved
Marie’s Psychological Incapacity. Marie denied all Leo’s allegations and also presented
an expert to prove her case. The RTC ruled against Marie and annulled the marriage.
The Matrimonial Tribunal of the church also annulled the marriage and was affirmed by
the Vatican’s Roman Rata. The CA reversed the decision hence the appeal.

Issue: Whether or not Psychological Incapacity is attendant to the case.

Held: Yes, Psychological Incapacity is attendant. The guidelines established in the

Molina case is properly established in the case at bar.

Rationale: 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 behaviour
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.