Scribd
Upload
25 views1 page

Nullity of Marriage: Antonio vs. Reyes

Leonilo Antonio filed a petition to have his marriage to Marie Ivonne Reyes declared null and void due to psychological incapacity under Article 36 of the Family Code. Reyes had persistently lied about many aspects of her life and had an illegitimate child she claimed was adopted. Experts testified that Reyes' constant lying and jealousy were abnormal and pathological. The court concluded Reyes was psychologically incapacitated and unable to comply with the obligations of marriage based on love, trust and respect. It declared the marriage null and void.

Uploaded by

Aljay Labuga
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
25 views1 page

Nullity of Marriage: Antonio vs. Reyes

Leonilo Antonio filed a petition to have his marriage to Marie Ivonne Reyes declared null and void due to psychological incapacity under Article 36 of the Family Code. Reyes had persistently lied about many aspects of her life and had an illegitimate child she claimed was adopted. Experts testified that Reyes' constant lying and jealousy were abnormal and pathological. The court concluded Reyes was psychologically incapacitated and unable to comply with the obligations of marriage based on love, trust and respect. It declared the marriage null and void.

Uploaded by

Aljay Labuga
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd

Antonio vs.

Reyes
GR No. 155800, March 10, 2006

FACTS:

Leonilo Antonio, 26 years of age, and Marie Ivonne Reyes, 36 years of age met in
1989. Barely a year after their first meeting, they got married at Manila City Hall and
then a subsequent church wedding at Pasig in December 1990. A child was born but
died 5 months later. Reyes persistently lied about herself, the people around her, her
occupation, income, educational attainment and other events or things. She even
did not conceal bearing an illegitimate child, which she represented to her husband
as adopted child of their family. They were separated in August 1991 and after
attempt for reconciliation, he finally left her for good in November 1991. Petitioner
then filed in 1993 a petition to have his marriage with Reyes declared null and void
anchored in Article 36 of the Family Code.

ISSUE: Whether Antonio can impose Article 36 of the Family Code as basis for
declaring their marriage null and void.

HELD:

Psychological incapacity pertains to the inability to understand the obligations of


marriage as opposed to a mere inability to comply with them. 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. Respondent’s fantastic ability to invent, fabricate stories
and letters of fictitious characters enabled her to live in a world of make-believe that
made her psychologically incapacitated as it rendered her incapable of giving
meaning and significance to her marriage. The root causes of Reyes’ psychological
incapacity have been medically or clinically identified that was sufficiently proven by
experts. The gravity of respondent’s 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. It would be difficult for an inveterate pathological liar to commit the basic
tenets of relationship between spouses based on love, trust and respect.
Furthermore, Reyes’ case is incurable considering that petitioner tried to reconcile
with her but her behavior remain unchanged.

Hence, the court conclude that petitioner has established his cause of action for
declaration of nullity under Article 36 of the Family Code.

You might also like