G.R. No. 155800 – 484 SCRA 353 – Civil Law – Persons and Family Relations – Family Code – Annulment of Marriage – Article 45 (3) distinguished from Psychological Incapacity (Article 36)
In 1990, Leonilo Antonio married Marie Ivonne Reyes, who was ten years older than Leonilo. In 1993, Leonilo filed a petition to annul their marriage due to the alleged psychological incapacity of Reyes. Leonilo claimed that Marie persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things. She would claim that she is a psychologist but she is not. She’d claim she is a singer with the company Blackgold and that she is the latter’s number 1 money maker but she’s not. She’d also spend lavishly as opposed to her monthly income. She fabricates things and people only to serve her make-believe world.
Leonilo presented an expert who testified to Reyes’s psychological incapacity. Reyes denied all of Leonilo’s allegations and she also presented an expert to prove her case. The RTC ruled against Reyes and declared their marriage void. Meanwhile, The Matrimonial Tribunal of the church also annulled the marriage and was even affirmed by the Vatican’s Roman Rata. However, the Court of Appeals reversed the decision hence the appeal.
ISSUE: Whether or not Marie Ivonne Reyes is psychologically incapacitated.
HELD: Yes, Reyes was proven to be psychologically incapacitated.
In this cases also, the Supreme Court emphasized what fraud or misrepresentation means as contemplated in Article 45 (3) of the Family Code vis-a-vis Article 46. The misrepresentation done by Reyes points to her inadequacy to cope with her marital obligations, kindred to psychological incapacity. In Article 45 (3), marriage may be annulled if the consent of either party was obtained by fraud, and Article 46 which enumerates the circumstances constituting fraud under the previous article, clarifies that “no other misrepresentation or deceit as to character, health, rank, fortune or chastity shall constitute such fraud as will give grounds for action for the annulment of marriage.” These provisions of Article 45 (3) and Article 46 cannot be applied in the case at bar because the misrepresentations done by Reyes is not considered as fraud but rather such misrepresentations constitute her aberrant behaviour which further constitutes Psychological Incapacity. Her misrepresentations are not lies sought to vitiate Leonilo’s consent to marry her. Her misrepresentations are evidence that Marie cannot simply distinguish fiction/fantasy from reality which is so grave and it falls under the fourth guideline laid down in the Molina Case.
