Sunday, October 6, 2019

ASSIGNMENT - DIGESTED CASE FOR GRANTED ANNULMENT CASE on the ground "Psychological Incapacity"


G.R. No. 155800

LEONILO ANTONIO, petitioner, vs. MARIE IVONNE F. REYES, respondent.

PONENTE:  Justice Tinga

FACTS:

            This is a Petition for Review on Certiorari which assails the Decision and Resolution of the Court of Appeals reversing the judgment of the Regional Trial Court of Makati declaring the marriage of Leonilo Antonio, petitioner and Marie Ivonne F. Reyes, respondent, null and void because 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 facts were culled from the decision of the Supreme Court.

Petitioner and respondent met sometime in August 1989 and a year after their first meeting, they got married before a minister at the Manila City Hall and through a church wedding at Sta. Rosa de Lima Parish, Pasig, City. They begot a child who sadly died five (5) months later.
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Petitioner filed a petition to have his marriage to respondent declared nulled and void which was anchored on Article 36 of the Family Code alleging that respondent was  psychologically incapacitated to comply with the essential obligations of marriage.  He asserted that respondent’s incapacity existed at the time their marriage was celebrated and still subsists up to the present.

Respondent’s alleged psychological incapacity as claimed by petitioner was manifested by respondent’s persistent lying about herself, the people around her, her occupation, income, educational attainment and other events or things.  Petitioner her extreme jealousy as respondent suspected her having an affair with another woman to the extent of calling up his officemates to monitor his whereabouts.  He tried to attempt a reconciliation but since her behavior did not change, he finally left her for good in November 1991.

Respondent opposed the petition claiming that she performed her marital obligations by attending the needs of her husband.  She presented her version and asserted that there was no truth to the allegations that she told lies, fabricated stories and invented personalities.

Petitioner presented Dr. Abcede, a psychiatrist, and Dr. Lopez, a clinical psychologist, who stated, based on the tests they conducted, petitioner is essentially normal, introspective, shy and conservative type of person.  They observed, on the other hand, that respondent’s constant lying to petitioner was abnormal and pathological as it undermined the basic relationship that should be based on love, trust and respect.  They concluded that respondent was psychologically incapacitated to perform her essential marital obligations.

Respondent presented a psychiatrist, Dr. Reyes and refuted the allegations anent her psychological condition. Dr. Reyes testified that the series of tests conducted by his assistant together with the screening procedures and the Comprehensive Psycho-Pathological Rating Scale (CPRS) he himself conducted, 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.

In rebuttal, Dr. Lopez asseverated that there were flaws in the evaluation conducted by Dr. Reyes as (1) he was not the one who administered and interpreted respondent’s psychological evaluation, and (2) he made use of only one instrument called CPRS which was not reliable because a good liar can fake the results of such test.

ISSUE:
            Whether or not the respondent’s persistent lying constitutes psychological incapacity that could be a ground of the nullity of her marriage to petitioner.

HELD:
            The Supreme Court held that the root cause of respondent’s psychological incapacity has been medically or clinically identified, alleged in the complaint, sufficiently proven by experts, and clearly explained in the trial court’s decision. The initiatory complaint alleged that respondent, from the start, had exhibited unusual and abnormal behavior “of perennially telling lies, fabricating ridiculous stories, and inventing personalities and situations,” of writing letters to petitioner using fictitious names, and of lying about her actual occupation, income, educational attainment, and family background, among others. 

The Supreme Court in support with its decision cited that although what is held in Marcos v. Marcos, 343 SCRA 755 (2000), that personal examination of the subject by the physician is not required for the spouse to be declared psychologically incapacitated, the Supreme Court considered the methodology utilized by petitioner’s witnesses as sufficient basis for their medical conclusions. Admittedly, Drs. Abcede and Lopez’s common conclusion of respondent’s psychological incapacity hinged heavily on their own acceptance of petitioner’s version as the true set of facts. However, since the trial court itself accepted the veracity of petitioner’s factual premises, there is no cause to dispute the conclusion of psychological incapacity drawn therefrom by petitioner’s expert witnesses.


The Supreme Court reversed the decision and resolution of the Court of Appeals and affirmed the decision of trial court instead.

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