Antonio vs.

Reyes
484 SCRA 353 GR No. 155800 March 10, 2006
Nature of Action:
This is a petition for review on certiorari of the decision and resolution of the
Court of Appeals reversing the judgment of Makati Regional Trial Court declaring the
marriage of Leonilo Antonio (petitioner) and Marie Ivonne Reyes (respondent), null and
void on the ground of psychological incapacity
Facts:

August 1989 when the respondent and petitioner met and then married a year
after. They had a child born on April 19, 1991 but died five (5) months later.

On March 8, 1993, petitioner filed a petition to declare their marriage null and
void on the ground of psychological incapacity to comply with the essential
obligation of marriage. He alleged that the respondent persistently lied about
herself, the people around her, her occupation, income, educational attainment
and other events or things such as concealing the fact that she gave birth to an
illegitimate son among other things.

The petitioner separated from the respondent in August 1991 though he tried to
attempt for reconciliation but failed. He finally left her for good in November 1991.

In contrast with the petitioners allegations, the respondent claimed that she
performed her marital obligations to her husband. She told that she only
concealed her illegitimate child out of fear of losing her husband but most of the
lies attributed to her were mostly hearsay.

Issue:
Whether or Not the petition to declare the marriage null and void on the ground of
psychological incapacity based on given facts meritorious
Held:
Yes. The guidelines set in the case of Republic vs. CA, also known as the Molina
case are applied to guide the courts in ruling on petitions for declaration of nullity of
marriage under Article 36 of the Family Code. However, the Molina doctrine is not set in
stone, meaning, the court shall take into consideration that cases are distinct from each
other.
It should be noted that the lies attributed to respondent were not adopted as false
pretenses in order to induce petitioner into marriage. The psychiatrists who came as
witnesses indicate that the respondent fails to distinguish truth from fiction. According to
them, this made her psychologically incapacitated as it rendered her incapable of giving
meaning and significance to her marriage.
Indeed, 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 of marriage including parenting. A person unable to grasp
reality cannot be expected to adhere to any legal or emotional commitments.
The petition was GRANTED, rendering their marriage null and void under Article
36 of the Family Code.