Antonio v. Reyes Tinga

ANTONIO V.
REYES TINGA
FACTS: Leonilo Antonio and Marie Reyes met in August 1989 when 26 and 36 years old respectively.
They got married a year after. On 8 March 1993, petitioner filed a petition to have his marriage to
respondent declared null and void because of the latter’s psychological incapacity. The following are
his allegations: (1) She concealed the fact that she previously gave birth to an illegitimate son and
instead introduced the boy as the adopted child of her family. (2) She fabricated a story that her
brother-in-law, Edwin David, attempted to rape and kill her when in fact, no such incident occurred.
(3) She misrepresented herself as a psychiatrist to her obstetrician, Dr. Consuelo Gardiner, and told
some of her friends that she graduated with a degree in psychology, when she was neither. (4) She
claimed to be a singer or a free-lance voice talent affiliated with Blackgold Recording Company which
is not true. (5) She invented friends named Babes Santos and Via Marquez, and under those names,
sent lengthy letters to petitioner claiming to be from Blackgold and touting her as the "number one
moneymaker" in the commercial industry worth P2 million. Petitioner later found out that
respondent herself was the one who wrote and sent the letters to him. (6) She represented herself as
a person of greater means, thus, she altered her payslip to make it appear that she earned a higher
income. She bought a sala set from a public market but told petitioner that she acquired it from a
famous furniture dealer. She spent lavishly on unnecessary items and ended up borrowing money
from other people on false pretexts. (7) She exhibited insecurities and jealousies over him to the
extent of calling up his officemates to monitor his whereabouts. When he could no longer take her
unusual behavior, he separated from her in August 1991. He tried to attempt a reconciliation but
since her behavior did not change, he finally left her for good in November 1991. Dr. Lopez, a clinical
psychologist, stated based on the tests they conducted that petitioner was essentially a normal,
introspective, shy and conservative type of person. On the other hand, they observed that
respondent’s persistent and constant lying to petitioner was abnormal or pathological.
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. Respondent presented Dr. Antonio Efren
Reyes, a psychiatrist, to refute the allegations anent her psychological condition. Dr. Reyes testified
that the series of tests conducted by his assistants 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. RTC
ruled in favor of the petitioner. CA reversed RTC’s judgment. Hence, this petition.
ISSUE: W/N Marie Reyes is psychologically incapacitated
HELD: Petitioner had sufficiently overcome his burden in proving the psychological incapacity of his
spouse. Apart from his own testimony, he presented witnesses who corroborated his allegations on
his wife’s behavior, and certifications from Blackgold Records and the Philippine Village Hotel Pavillon
which disputed respondent’s claims pertinent to her alleged singing career. The root cause of
respondent’s psychological incapacity has been medically or clinically identified and proven by
experts. And Catholic Church annulled their marriage. Indeed, a person unable to distinguish between
fantasy and reality would similarly be unable to comprehend the legal nature of the marital bond,
much less its psychic meaning, and the corresponding obligations attached to marriage, including
parenting. One unable to adhere to reality cannot be expected to adhere as well to any legal or
emotional commitments

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ANTONIO V.

ISSUE: W/N Marie Reyes is psychologically incapacitated

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