( On Psychological Incapacity as ground for Annulment of Marriage)
G.R. No. 155800, March 10, 2006
LEONILO ANTONIO Petitioner,vs.
MARIE IVONNE F. REYES, Respondent.
Facts:
Antonio and Reyes was married on 6 December 1990, bore child on 1993 but only died 5mos. On 8 March 1993, petitioner filed a petition to have his marriage to respondent declared null and void. He anchored his petition for nullity on Article 36 of the Family Code alleging that respondent was psychologically incapacitated to comply with the essential obligations of marriage. respondent’s persistent and constant lying to petitioner was abnormal or pathological. It undermined the basic relationship that should be based on love, trust and respect. Comprehensive Psycho-Pathological Rating Scale (CPRS), dr. Reyes, (respondent) Dr. Lopez, psychologist, psychiatrist, Dr.Abcede
As manifestations of respondent’s alleged psychological incapacity, petitioner claimed that respondent persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things. In support of this claim, he presented doctors. 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.
After trial, the lower court gave credence to petitioner’s evidence and held that respondent’s propensity to lying about almost anything−her occupation, state of health, singing abilities and her income, among others−had been duly established. According to the trial court, respondent’s fantastic ability to invent and fabricate stories and personalities enabled her to live in a world of make-believe. This made her psychologically incapacitated as it rendered her incapable of giving meaning and significance to her marriage. The trial court thus declared the marriage between petitioner and respondent null and void.
Shortly before the trial court rendered its decision, the Metropolitan Tribunal of the Archdiocese of Manila annulled the Catholic marriage of the parties, on the ground of lack of due discretion on the part of the parties.
The appellate court reversed the RTC’s judgment. While conceding that respondent may not have been completely honest with petitioner, the Court of Appeals nevertheless held that the totality of the evidence presented was insufficient to establish respondent’s psychological incapacity.
Issue:
Whether the state of facts as presented by petitioner sufficiently meets the standards set for the declaration of nullity of a marriage under Article 36 of the Family Code.
Yes, the case sufficiently meet the Molina Guidelines. Molina established the guidelines presently recognized in the judicial disposition of petitions for nullity under Article 36. The Court has consistently applied Molina since its promulgation in 1997, and the guidelines therein operate as the general rules. The notion that psychological incapacity pertains to the inability to understand the obligations of marriage, as opposed to a mere inability to comply with them, was further affirmed in the Molina66 case. Therein, the Court, through then Justice (now Chief Justice) Panganiban observed that “[t]he evidence [to establish psychological incapacity] must convince the court that the parties, or one of them, was mentally or psychically ill to such extent that the person could not have known the obligations he was assuming, or knowing them, could not have given valid assumption thereto.”
Article 36 of the Family Code states that “[a] marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization.”
Therefore, marriage between petitioner and respondent is NULL and VOID under Article 36 of the Family Code.
Real LexEcon 