SC declares marriage void because wife is a liar


How can a liar be a faithful, loving, trusting, trustworthy, respectful and respectable wife? This is the question that settled the issue in one case where the marriage was declared null and void because the husband was able to prove that his wife cannot stop herself from lying about everything.

In his opening paragraph in Antonio v. Reyes (G.R. No. 155800), Justice Tinga wrote: "Statistics never lie, but lovers often do, quipped a sage. This sad truth has unsettled many a love transformed into matrimony. Any sort of deception between spouses, no matter the gravity, is always disquieting. Deceit to the depth and breadth unveiled in the following pages, dark and irrational as in the modern noir tale, dims any trace of certitude on the guilty spouse’s capability to fulfill the marital obligations even more."

In the above-mentioned case decided by the High Court on March 10, 2006, it was held that being a "pathological liar" is a ground to declare the nullity of the marriage (as void ab initio) on the ground of psychological incapacity under Article 36 of the Family Code of the Philippines.

In that case, the wife persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things. The husband gave the following examples:

[1] She concealed the fact that she previously gave birth to an illegitimate son, and instead introduced the boy to the husband as the adopted child of her family. She only confessed the truth about the boy’s parentage when the husband learned about it from other sources after their marriage.

[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 (Blackgold); yet, not a single member of her family ever witnessed her alleged singing activities with the group. In the same vein, she postulated that a luncheon show was held at the Philippine Village Hotel in her honor and even presented an invitation to that effect but the husband discovered per certification by the Director of Sales of said hotel that no such occasion had taken place.

[5] She invented friends named Babes Santos and Via Marquez, and under those names, sent lengthy letters to the husband claiming to be from Blackgold and touting her as the "number one moneymaker" in the commercial industry worth P2 million. The husband later found out that the wife herself was the one who wrote and sent the letters to him when she admitted the truth in one of their quarrels.

He likewise realized that Babes Santos and Via Marquez were only figments of her imagination when he discovered they were not known in or connected with Blackgold.

[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 the husband 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.

Article 36 of the Family Code states that "[a] marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest only after its solemnization." The concept of psychological incapacity as a ground for nullity of marriage is novel in our body of laws, although mental incapacity has long been recognized as a ground for the dissolution of a marriage.

Luckily, the husband was sufficiently able to 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 the wife's claims pertinent to her alleged singing career. He also presented two (2) expert witnesses from the field of psychology who testified that the aberrant behavior of the wife was tantamount to psychological incapacity. In any event, both courts below considered the husband's evidence as credible enough. Even the appellate court acknowledged that she was not totally honest with the husband.

The root cause of the wife'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 the wife, from the start, had exhibited unusual and abnormal behavior "of peren[n]ially telling lies, fabricating ridiculous stories, and inventing personalities and situations," of writing letters to her husband using fictitious names, and of lying about her actual occupation, income, educational attainment, and family background, among others.

To summarize the ruling of the Supreme Court, it was held: "[The wife] is evidently unable to comply with the essential marital obligations as embraced by Articles 68 to 71 of the Family Code. Article 68, in particular, enjoins the spouses to live together, observe mutual love, respect and fidelity, and render mutual help and support. As noted by the trial court, it is difficult to see how an inveterate pathological liar would be able to commit to the basic tenets of relationship between spouses based on love, trust and respect."

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