Cindy Climaco

Lying as a Ground to Declare a Marriage Void from the Beginning

On 10 March 2006, the Supreme Court issued a decision in the case of Antonio vs. Reyes, GR. No. 155800, March 10, 2006, declaring the marriage void from the beginning under Article 36 of the Family Code of the Philippines, on the ground that the wife, being a pathological liar, is psychologically incapacitated at the time of the celebration of marriage.

Article 36 of the Family Code provides 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.

In the case at hand, Respondent persistently lied about herself, the people around her, her occupation, income, educational attainment and other events or things, to wit:

  1. Respondent concealed the fact that she previously gave birth to an illegitimate son, and instead introduced the boy to Petitioner as the adopted child of her family. Respondent only confessed the truth about the boy’s parentage when Petitioner learned about it from other sources after their marriage.
  2. Respondent fabricated a story that her brother-in-law, attempted to rape and kill her when in fact, no such incident occurred.
  3. Respondent misrepresented herself as a psychiatrist to her obstetrician and told some of her friends that she graduated with a degree in psychology when she was neither.
  4. Respondent 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, Respondent postulated that a luncheon show was held at the Philippine Village Hotel in her honor and even presented an invitation to that effect but Petitioner discovered per certification by the Director of Sales of the said hotel that no such occasion had taken place.
  5. Respondent 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 when she admitted the truth in one of their quarrels. Petitioner likewise realized that Babes Santos and Via Marquez were only figments of Respondent’s imagination when he discovered they were not known in or connected with Blackgold.
  6. Respondent represented herself as a person of greater means, thus, she altered her payslip to make it appear that she earned a higher income. Respondent bought a sala set from a public market but told the petitioner that she acquired it from a famous furniture dealer. Respondent spent lavishly on unnecessary items and ended up borrowing money from other people on false pretexts.
  7. Respondent exhibited insecurities and jealousies over Petitioner to the extent of calling up his officemates to monitor his whereabouts


Being a pathological liar, Respondent is unable to comply with the essential marital obligations provided under Article 68 of the Family Code. Article 68 provides that, “The husband and wife are obliged to live together, observe mutual love, respect, and fidelity, and render mutual help and support”.

As testified by the expert witness, persistent lying violates the respect that one owes towards another. The relationship is based on communication between individuals. If you constantly lie, it undermines the basic relationship that should be based on love, trust, and respect. The Court also observes that the actuations of Respondent are indications that she is psychologically incapacitated to perform the essential obligations of marriage. It has been shown clearly from Respondent’s actuations that she has that propensity for telling lies about almost anything, be it her occupation, her state of health, her singing abilities, her income, etc. Respondent has this fantastic ability to invent and fabricate stories and personalities.

She practically lived in a world of make-believe making her therefore not in a position to give meaning and significance to her marriage to the petitioner. In persistently and constantly lying to Petitioner, Respondent undermined the basic tenets of relationship between spouses that is based on love, trust, and respect. As concluded by the psychiatrist presented by the petitioner, such repeated lying is abnormal and pathological and amounts to psychological incapacity.


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