FACTS: In 1990, Leo married Marie, the latter being ten years his senior. In 1993, Leo filed to annul the marriage due to Marie’s Psychological Incapacity. Leo 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. Leo presented an expert that proved Marie’s PI. Marie denied all Leo’s allegations and also presented an expert to prove her case. The RTC ruled against Marie and annulled the marriage. The Matrimonial Tribunal of the church also annulled the marriage and was affirmed by the Vatican’s Roman Rata. The CA reversed the decision hence the appeal.
ISSUE: Whether or not PI is attendant to the case.
HELD: Yes, Psychological Incapacity is attendant. The guidelines established in the Molina case is properly established in the case at bar.
The SC also emphasized what fraud means as contemplated in Art 45 (3) of the FC vis a vis Art 46 of the FC. In PI, the misrepresentation done by Marie points to her inadequacy to cope with her marital obligations, kindred to psychological incapacity. In Art 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 Art 45 (3) and Art 46 cannot be applied in the case at bar because the misrepresentations done by Marie is not considered as fraud but rather such misrepresentations constitute her aberrant behaviour which further constitutes PI. Her misrepresentations are not lies sought to vitiate Leo’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.