Civil Law,  Legally Yours

Antonio v. Reyes

Civil Law. Persons and Family Relations. Article 36 Family Code. Psychological Incapacity.
ANTONIO v. REYES
G.R. 155800; March 10, 2006

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. On March 8, 1993, petitioner filed a petition to have his marriage declared null and void on the ground of his wife’s psychological incapacity as manifested by her persistent lying about herself and other things. The lower court gave credence to the petitioner’s evidence but the appellate court reversed the decision, thus the petition for certiorari

ISSUE:
Can petitioner invoke Article 36 of the Family Code as a ground for the declaration of nullity of his marriage?

HELD:
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.

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