G.R. No. 155800 ; March 10, 2006
LEONILO ANTONIO, Petitioner, vs. MARIE IVONNE F. REYES, Respondent.

FACTS

Petitioner Leonilo Antonio sought the nullity of his marriage to respondent Marie Ivonne Reyes under Article 36 of the Family Code, alleging her psychological incapacity. He claimed that from courtship through marriage, respondent engaged in persistent and elaborate fabrications. These included concealing an illegitimate child, falsely claiming a brother-in-law attempted to rape her, misrepresenting herself as a psychiatrist and a recording artist, inventing fictitious friends who sent laudatory letters, and falsifying her income. Petitioner presented expert testimony from a psychiatrist and a clinical psychologist, who diagnosed respondent with a pathological lying condition and extreme, baseless jealousy amounting to paranoia, which they concluded utterly undermined marital trust and respect.
The Regional Trial Court granted the petition and declared the marriage null and void. The Court of Appeals reversed this decision, finding that respondent’s behavior, while regrettable, did not constitute the grave psychological incapacity contemplated by law. The appellate court characterized her actions as mere pretense, deceit, and lying, which did not rise to the level of a serious personality disorder. Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether or not respondent’s established pattern of pathological lying and associated behavior constitutes psychological incapacity to comply with the essential marital obligations under Article 36 of the Family Code.

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the trial court’s judgment declaring the marriage null and void. The Court held that respondent’s condition constituted psychological incapacity. Applying the guidelines in Santos v. CA and Molina, the Court found the incapacity to be grave, rooted in her history prior to the marriage, and incurable. The pervasive and compulsive nature of her fabrications was not mere simple lying but a pathological condition that demonstrated an utter inability to understand and perform the fundamental marital covenants of love, trust, respect, and fidelity. Her behavior was not just injurious but destructive of the very foundation of the marital relationship. The expert testimony credibly established that this condition was a serious personality disorder existing at the time of the wedding. Consequently, her incapacity was juridically antecedent, and the marriage was declared void ab initio.