FACTS: Leonilo Antonio
and Marie Reyes met in August 1989 when 26 and 36 years old respectively. They
got married a year after. On 8 March 1993, petitioner filed a petition to have
his marriage to respondent declared null and void because of the latter’s
psychological incapacity. The following are his allegations: (1) She concealed
the fact that she previously gave birth to an illegitimate son and instead
introduced the boy as the adopted child of her family. (2) She fabricated a
story that her brother-in-law, Edwin David, attempted to rape and kill her when
in fact, no such incident occurred. (3) She misrepresented herself as a
psychiatrist to her obstetrician, Dr. Consuelo Gardiner, and told some of her
friends that she graduated with a degree in psychology, when she was neither.
(4) She claimed to be a singer or a free-lance voice talent affiliated with
Blackgold Recording Company which is not true. (5) She invented friends named
Babes Santos and Via Marquez, and under those names, sent lengthy letters to
petitioner claiming to be from Blackgold and touting her as the "number
one moneymaker" in the commercial industry worth P2 million. Petitioner
later found out that respondent herself was the one who wrote and sent the
letters to him. (6) She represented herself as a person of greater means, thus,
she altered her payslip to make it appear that she earned a higher income. She
bought a sala set from a public market but told petitioner that she acquired it
from a famous furniture dealer. She spent lavishly on unnecessary items and
ended up borrowing money from other people on false pretexts. (7) She exhibited
insecurities and jealousies over him to the extent of calling up his
officemates to monitor his whereabouts. When he could no longer take her
unusual behavior, he separated from her in August 1991. He tried to attempt a
reconciliation but since her behavior did not change, he finally left her for
good in November 1991. Dr. Lopez, a clinical psychologist, stated based on the
tests they conducted that petitioner was essentially a normal, introspective,
shy and conservative type of person. On the other hand, they observed that
respondent’s persistent and constant lying to petitioner was abnormal or
pathological.
In opposing the
petition, respondent claimed that she performed her marital obligations by attending
to all the needs of her husband. She asserted that there was no truth to the
allegation that she fabricated stories, told lies and invented personalities.
Respondent presented Dr. Antonio Efren Reyes, a psychiatrist, to refute the
allegations anent her psychological condition. Dr. Reyes testified that the
series of tests conducted by his assistants led him to conclude that respondent
was not psychologically incapacitated to perform the essential marital
obligations. He postulated that regressive behavior, gross neuroticism,
psychotic tendencies, and poor control of impulses, which are signs that might
point to the presence of disabling trends, were not elicited from respondent.
RTC ruled in favor of the petitioner. CA reversed RTC’s judgment. Hence, this
petition.
ISSUE: W/N Marie Reyes
is psychologically incapacitated
HELD: Petitioner had
sufficiently overcome his burden in proving the psychological incapacity of his
spouse. Apart from his own testimony, he presented witnesses who corroborated
his allegations on his wife’s behavior, and certifications from Blackgold
Records and the Philippine Village Hotel Pavillon which disputed respondent’s
claims pertinent to her alleged singing career. The root cause of respondent’s
psychological incapacity has been medically or clinically identified and proven
by experts. And Catholic Church annulled their marriage. Indeed, a person
unable to distinguish between fantasy and reality would similarly be unable to
comprehend the legal nature of the marital bond, much less its psychic meaning,
and the corresponding obligations attached to marriage, including parenting.
One unable to adhere to reality cannot be expected to adhere as well to any
legal or emotional commitments
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