ANTONIO V.

REYES
Leonilo Antonio was married to Marrie Yvonne Reyes on Dec 6, 1990. They had a child who
died 5 months later. Reyes concealed the fact that she previously had an illegitimate son
introducing the boy as an adopted child of the family. She fabricated a story that her brother-
in-law attempted to rape and kill her. She misrepresented herself as a psychiatrist. She
claimed to be a successful singer when no member of her family witnessed her alleged singing
activities. She invented friends from the music industry who wrote letters to Antonio touting
her as the number one moneymaker. Antonio later found out that she was the one who
actually wrote and sent the letters. She altered her pay slip to represent herself as one of
greater means. She exhibited insecurities and jealousies over Antonio to the extent of calling
his officemates to monitor his whereabouts. On Mar 8, 1993, Antonio filed a petition to have
their marriage declared null and void and presented two expert witnesses who concluded that
her persistent lying and paranoia made her psychologically incapacitated to perform her
marriage obligations. While the case was pending, on Mar 30, 1995, the marriage of the
parties was annulled by the Catholic Church. RTC granted the petition, CA reversed.

ISSUE: WON Marrie Yvonne Reyes was psychologically incapacitated.

HELD: YES. Petition granted. Marriage VOID.

RATIO:
1. A person unable to distinguish between fantasy and reality would similarly be unable to
comprehend the legal nature of the marital bond and the corresponding obligations
attached to marriage.
2. Present case sufficiently satisfies guidelines in MOLINA (REP. V. CA). Psychological
incapacity was sufficiently proven by expert witnesses & root cause has been medically
identified. It clearly existed at the time of and even before the marriage. Its gravity is
sufficient to prove her disability to assume the essential obligations of marriage based
on love, trust and respect.
3. MOLINA (1997) is not set in stone and interpretation of Art 36 FC relies heavily on a
case-to-case perception. Clinical diagnosis of incurability was not yet required when
expert witnesses testified in 1994-95. SANTOS V. CA, promulgated by the SC in Jan
1995, in its doctrinal rule omitted any reference to incurability as a characteristic of
psychological incapacity. Hence, there was no legal impelling cause to prove
incurability during trial. In this case, Court is convinced by the totality of the evidence
that Reyes psychological incapacity is incurable.
4. Conclusion of canonical bodies, though not controlling, hold sway since they were
drawn from a similar recognition as the trial court.