CAMACHO- REYES v REYES

Facts:

Petitioner Maria Socorro Camacho-Reyes met respondent Ramon Reyes at UP Diliman, in 1972
when they were both 19. They were simply classmates then in a subject when Ramos crossenrolled from the UP Los Baos campus.

The casual acquaintanceship quickly developed into a boyfriend-girlfriend relationship. Maria was
initially attracted to Ramon who she thought was free spirited and bright, although he did not
follow conventions and traditions.

Since both resided in Mandaluyong City, they saw each other every day and drove home together
from the university.

Easily impressed, Ramons style of courtship included dining out, unlike other couples their age
who were restricted by a university students budget. At that time, he held a job in the family
business, the Aristocrat Restaurant.

Marias good impression of Ramon was not diminished by the latters habit of cutting classes, not
even by her discovery that respondent was taking marijuana.

Only Maria finished university studies, obtaining a degree in AB Sociology from the UP. Ramon
dropped out of school in his third year, and just continued to work for the Aristocrat Restaurant.

After her graduation and her fathers death, they got married. At that time, she was already 5
months pregnant and employed at the Population Center Foundation.

Thereafter, the newlyweds lived with Ramons family in Mandaluyong City. All living expenses were
shouldered by his parents. Initially, he gave her a monthly allowance of P1,500.00 from his salary.

When their first child was born, financial difficulties started. Rearing a child entailed expenses. A
year into their marriage, the monthly allowance from Ramon stopped. Further, he no longer
handed his salary to Maria. He told her that he had resigned due to slow advancement within the
family business. His plan was to venture into trading seafood in the province, supplying hotels and
restaurants, including the Aristocrat Restaurant. However, this new business took him away from
his young family for days on end without any communication.

To prod him into assuming more responsibility, Maria suggested that they live separately from her
in-laws. However, the new living arrangement engendered further financial difficulty. While she
struggled as the single-income earner of the household, Ramons business floundered. Thereafter,
another attempt at business, a fishpond in Mindoro, was similarly unsuccessful.

That his business took him away from his family did not seem to bother him; he did not exert any
effort to remain in touch with them while he was away in Mindoro.

After two (2) years of struggling, the spouses transferred residence and, this time, moved in with
Marias mother. The parties became more estranged. She continued to carry the burden of
supporting a family not just financially, but in most aspects as well.

Maria, who had previously suffered a miscarriage, gave birth to their third son. At that time, he was
in Mindoro and he did not even inquire on the health of either Maria or the newborn. A week later,
he arrived in Manila, acting nonchalantly while playing with the baby, with nary an attempt to find
out how the hospital bills were settled.

Due to financial reverses, Ramons fishpond business stopped operations. He refused to go back to
work for the family business but came up with another business venture, engaging in scrap paper
and carton trading. Again, this did not succeed and added to the trail of debt. The relationship of
the parties continued to deteriorate.

Years after, Maria confirmed that Ramon was having an extra-marital affair. She overheard him
talking to his girlfriend, a former secretary, over the phone inquiring if the latter liked respondents
gift to her.

One of the last episodes that sealed the fate of the parties marriage was a surgical operation on
Maria for the removal of a cyst. He remained unconcerned and unattentive. After the operation,
she asked her mother to order him to leave the recovery room.

She approached his siblings and asked them to intervene. Adolfo Reyes, Ramons elder brother,
and his spouse, Peregrina, members of a marriage encounter group, invited and sponsored the
parties to join the group. The elder couple scheduled counseling sessions with them, but these did
not improve the parties relationship as Ramon remained uncooperative.

Adolfo brought respondent to Dr. Natividad Dayan for a psychological assessment to determine
benchmarks of current psychological functioning. As with all other attempts to help him, he
resisted and did not continue with the clinical psychologists recommendation to undergo
psychotherapy.

Maria told Ramon to move out of their house. He acquiesced to give her space. With the de
facto separation, the relationship still did not improve.
Finally, Maria filed a petition for the declaration of nullity of her marriage with the RTC, alleging the
Ramons psychological incapacity to fulfill the essential marital obligations under Article 36 (FC).
Ramon denied petitioners allegations that he was psychologically incapacitated. He maintained he
was not remiss in performing his obligations to his family both as a spouse and father.
After trial (where the testimonies of two clinical psychologists, Dr. Dayan and Dr. Estrella Magno,
and a psychiatrist, Dr. Cecilia Villegas, were presented in evidence), the RTC granted the petition
and declared their marriage null and void on the ground of their psychological incapacity.
Ramon appealed to the Court of Appeals, which agreeing with him and reversed the RTC.
o Generally, expert opinions are regarded, not as conclusive, but as purely advisory in
character. A court may even reject them, if it finds that they are inconsistent with the facts
of the case or are otherwise unreasonable.
o In the instant case, neither clinical psychologist Magno nor psychiatrist Dr. Villegas
conducted a psychological examination on the [respondent]. Undoubtedly, the
assessment and conclusion made by Magno and Dr. Villegas are hearsay.
o
[I]t can be gleaned from the recommendation of Dayan that the purported psychological
incapacity of Ramon is not incurable as there is a way to cure it through individual therapy
and counseling sessions.
o [Respondents] defects were not present at the inception of marriage. They were even able
to live in harmony in the first few years of their marriage, which bore them two children.
o Psychological incapacity must be more than just a difficulty, a refusal or a neglect in the
performance of some marital obligations, it is essential that they must be shown to
be incapable of doing so, due to some psychological illness existing at the time of the
celebration of the marriage.
At bar is a petition for review on certiorari filed by Maria, assailing the decision of the CA.

ISSUE: WON the marriage between the parties is void ab initio on the ground of both parties
psychological incapacity - YES
RATIO:

Article 36 of the Family Code reads:

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
solemnization.
Article 36 does not define what psychological incapacity means. It left the determination of
the same solely to the Court on a case to case basis. Meanwhile, Art. 68 provides:
The husband and wife are obliged to live together, observe mutual love, respect and
fidelity, and render mutual help and support.
Similarly, Articles 69-71 further define the mutual obligations of a marital partner towards
each other and Articles 220, 225 and 271 of the Family Code express the duties of parents
toward their children.

Santos v. Court of Appeals: the factors characterizing psychological incapacity to perform the
essential marital obligations are: (1) gravity, (2) juridical antecedence, and (3) incurability. The
incapacity must be grave or serious such that the party would be incapable of carrying out the
ordinary duties required in marriage; it must be rooted in the history of the party antedating the
marriage, although the overt manifestations may emerge only after the marriage; and it must be
incurable or, even if it were otherwise, the cure would be beyond the means of the party involved.
As previously adverted to, the three experts were one in diagnosing respondent with a personality
disorder, to wit:
1. Dra. Cecilia C. Villegas (examined both of their family histories, interviewed Maria), :
Maria manifested inadequacies along her affective sphere, that made her less responsive to
the emotional needs of her husband, who needed a great amount of it, rendering her relatively
psychologically incapacitated to perform the duties and responsibilities of marriage.

[Respondent], on the other hand, has manifested strong clinical evidence, that he is
suffering from a Personality Disorder, of the antisocial type, associated with strong
sense of Inadequacy along masculine strivings and narcissistic features that
renders him psychologically incapacitated to perform the duties and responsibilities
of marriage.His being a free spirit associated with no remorse, no guilt feelings
and no anxiety, is distinctive of this clinical condition. His prolonged drug intake
[marijuana] and maybe stronger drugs lately, are external factors to boost his ego.
The root cause of the above clinical conditions is due to his underlying defense
mechanisms, or the unconscious mental processes, that the ego uses to resolve
conflicts. His prolonged and closed attachments to his mother encouraged cross identification
and developed a severe sense of inadequacy specifically along masculine strivings. He
therefore has to camouflage his weakness, in terms of authority, assertiveness, unilateral and
forceful decision making, aloofness and indifference, even if it resulted to antisocial acts. His
narcissistic supplies rendered by his mother was not resolved (sic). It existed before
marriage, but became manifest only after the celebration, due to marital demands
and stresses. It is considered as severe and permanent in nature because it has became so
engrained into his personality.
2. Dr. Natividad A. Dayan (interviewed Ramons siblings and probably Maria too)
In his relationships with people, [respondent] is apt to project a reserved, aloof and detached
attitude. [Respondent] exhibits withdrawal patterns. He has deep feelings of inadequacy. Due
to a low self-esteem, he tends to feel inferior and to exclude himself from association with
others. He feels that he is different and as a result is prone to anticipate rejections. Because of
this, he is apt to avoid personal and social involvement, which increases his preoccupation with
himself and accentuates his tendency to withdraw from interpersonal contact. [Respondent] is
also apt to be the less dominant partner. He feels better when he has to follow than when he
has to take the lead. He has a small need of companionship and is most comfortable alone. He,
too[,] feels uncomfortable in expressing his more tender feelings for fear of being hurt.
Likewise, he maybe very angry within but he may choose to repress this feeling. This is likely
to result in anger and frustrations which is likewise apt to be repressed.
There are indications that [respondent] is[,] at the moment[,] experiencing considerable
tension and anxiety. He is prone to fits of apprehension and nervousness. Likewise, he is also
entertaining feelings of hopelessness and is preoccupied with negative thought. He feels that
he is up in the air but with no sound foundation. He has difficulty concentrating and focusing
on things which he needs to prioritize. This feeling of hopelessness is further aggravated by
the lack of support from significant others.
Diagnostic Impression: Drug Dependence, Mixed Personality Disorder [Schizoid,
Narcissistic and Antisocial Personality Disorder], Severe Psychosocial and Environmental
Problems
3. Dr. Estrella T. Tiongson-Magno (looked at both their childhoods, interviewed petitioner)
From the evidence available from [petitioners] case history and from her
psychological assessment, and despite the non-cooperation of the respondent, it is
possible to infer with certainty the nullity of this marriage. Based on the
information available about the respondent, he suffers from [an] antisocial
personality disorder with narcissistic and dependent features that renders him too
immature and irresponsible to assume the normal obligations of a marriage. As for
the petitioner, she is a good, sincere, and conscientious person and she has tried her best to
provide for the needs of her children. But she is emotionally immature and her comprehension
of human situations is very shallow for a woman of her academic and professional
competence. And this explains why she married Ramon even when she knew he was a
pothead, then despite the abuse, took so long to do something about her situation.
Diagnosis for [petitioner]: Partner Relational Problem, Obsessive Compulsive Personality
Style with Self-Defeating features, Psychosocial Stressors-Pervasive Family Discord (spouses
immaturity, drug abuse, and infidelity)

Diagnosis for [respondent]: Partner Relational Problem, Antisocial Personality Disorder

with marked narcissistic, aggressive sadistic and dependent features, Psychosocial
Stressors-Pervasive Family Discord (successful wife)
[Respondents] narcissistic personality features were manifested by his self-centeredness
(e.g. moved to Mindoro and lived there for 10 years, leaving his family in Manila); his grandiose
sense of self-importance (e.g. he would just come and go, without telling his wife his
whereabouts, etc.); his sense of entitlement (e.g. felt entitled to a mistress because
[petitioner] deprived him of his marital rights, etc.); interpersonally exploitative (e.g. let his
wife spend for all the maintenance needs of the family, etc.); and lack of empathy (e.g. when
asked to choose between his mistress and his wife, he said he would think about it, etc.)
The aggressive sadistic personality features were manifested whom he has physically,
emotionally and verbally abusive of his wife when high on drugs; and his dependent
personality features were manifested by his need for others to assume responsibility for most
major areas of his life, and in doing things on his own.

The lack of personal examination and interview of the respondent, or any other person diagnosed
with personality disorder, does not per se invalidate the testimonies of the doctors. Neither do
their findings automatically constitute hearsay that would result in their exclusion as evidence.
o For one, marriage necessarily involves only two persons. The totality of the behavior of one
spouse during the cohabitation and marriage is generally and genuinely witnessed mainly
by the other. Certainly, petitioner, during their marriage, had occasion to interact with, and
experience, respondents pattern of behavior which she could then validly relay to the
clinical psychologists and the psychiatrist.
o Other informants such as respondents own son, siblings and in-laws, and sister-in-law
(sister of petitioner), testified on their own observations of respondents behavior and
interactions with them.
o The recent case of Lim v. Sta. Cruz-Lim1, explains that doctors can diagnose the
psychological make up of a person based on a number of factors culled from various
sources. A person afflicted with a personality disorder will not necessarily have personal
knowledge thereof. In this case, considering that a personality disorder is manifested in a
pattern of behavior, self-diagnosis by the respondent consisting only in his bare
denial, does not necessarily evoke credence and cannot trump the findings of
experts.
A recommendation for therapy does not automatically imply curability. In general,
recommendations for therapy are given by clinical psychologists, or even psychiatrists, to manage
behavior.

1 citing The Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM IV) instructs us on thegeneral diagnostic
criteria for personality disorders:A. An enduring pattern of inner experience and behavior that deviates markedly from the
expectations of the individual's culture. This pattern is manifested in two (2) or more of the following areas:
(1) cognition (i.e., ways of perceiving and interpreting self, other people, and events)
(2) affectivity (i.e., the range, intensity, liability, and appropriateness of emotional response)
(3) interpersonal functioning
(4) impulse control
B.
The enduring pattern is inflexible and pervasive across a broad range of personal and social situations.
C.
The enduring pattern leads to clinically significant distress or impairment in social, occupational or other important areas of
functioning.
D. The pattern is stable and of long duration, and its onset can be traced back at least to adolescence or early adulthood.
E.
The enduring pattern is not better accounted for as a manifestation or a consequence of another mental disorder.
F.
The enduring pattern is not due to the direct physiological effects of a substance (i.e., a drug of abuse, a medication) or a
general medical condition (e.g., head trauma).
Specifically, the DSM IV outlines the diagnostic criteria for Antisocial Personality Disorder:
A. There is a pervasive pattern of disregard for and violation of the rights of others occurring since age 15 years, as indicated by
three (or more) of the following:
(1) failure to conform to social norms with respect to lawful behaviors as indicated by repeatedly performing acts that are grounds
for arrest
(2) deceitfulness, as indicated by repeated lying, use of aliases, or conning others for personal profit or pleasure
(3) impulsivity or failure to plan ahead
(4) irritability and aggressiveness, as indicated by repeated physical fights or assaults
(5) reckless disregard for safety of self or others
(6) consistent irresponsibility, as indicated by repeated failure to sustain consistent work behavior or honor financial obligations
(7) lack of remorse as indicated by being indifferent to or rationalizing having hurt, mistreated, or stolen from another
B. The individual is at least 18 years.
C. There is evidence of conduct disorder with onset before age 15 years.
D. The occurrence of antisocial behavior is not exclusively during the course of schizophrenia or a manic episode. [20]

In Kaplan and Saddocks textbook entitled Synopsis of Psychiatry, [21] treatment, ranging
from psychotherapy to pharmacotherapy, for all the listed kinds of personality disorders
are recommended.
o Dr. Dayan, during her testimony, categorically declared that respondent is psychologically
incapacitated to perform the essential marital obligations.
We find points of convergence & consistency in all three reports and the respective testimonies of
Doctors Magno, Dayan and Villegas, i.e.: (1) respondent does have problems; and (2) these
problems include chronic irresponsibility; inability to recognize and work towards providing the
needs of his family; several failed business attempts; substance abuse; and a trail of unpaid
money obligations.
It is true that a clinical psychologists or psychiatrists diagnoses that a person has personality
disorder is not automatically believed by the courts in cases of declaration of nullity of marriages.
Indeed, a clinical psychologists or psychiatrists finding of a personality disorder does not exclude a
finding that a marriage is valid and subsisting.
Even
without
the
experts
conclusions,
the
factual
antecedents alleged in the petition and established during trial, all point to the inevitable
conclusion that respondent is psychologically incapacitated to perform the essential marital
obligations.
o

SC Conclusion on Ramon: PSYCHOLOGICALLY INCAPACITATED

His behavior manifests an inability, nay, a psychological incapacity to perform the essential marital
obligations as shown by his: (1) sporadic financial support; (2) extra-marital affairs; (3) substance
abuse; (4) failed business attempts; (5) unpaid money obligations; (6) inability to keep a job that is not
connected with the family businesses; and (7) criminal charges of estafa.
SC Conclusion on Maria: NOT PSYCHOLOGICALLY INCAPACITATED
The Amended Petition shows that it failed to specifically allege the complete facts showing that
petitioner was psychologically incapacitated from complying with the essential marital obligations of
marriage at the time of the celebration of marriage. What was merely prayed for in the said Amended
Petition is that judgment be rendered declaring the marriage between them void ab initio on the
ground of psychological incapacity of Ramon.