Camacho-Reyes vs.

Reyes
G.R. No. 185286 August 18, 2010
FACTS:
Petitioner Maria Socorro Camacho-Reyes and respondent Ramon Reyes got
married in December 5, 1976. At that time, petitioner was already five (5)
months pregnant.
When their first child was born on March 22, 1977, financial difficulties
started. Respondent no longer handed his salary to petitioner.
Compounding the familys financial woes and further straining the parties
relationship was the indifferent attitude of respondent towards his family.
Sometime in 1996, petitioner confirmed that respondent was having an extramarital affair.
Finally, in 2001, petitioner filed (before the RTC) a petition for the declaration
of nullity of her marriage with the respondent, alleging the latters
psychological incapacity to fulfill the essential marital obligations under
Article 36 of the Family Code.
The RTC granted the petition and declared the marriage between the parties
null and void.
Respondent appealed to the Court of Appeals which then reversed the RTC
and declared the parties marriage as valid and subsisting.
Petitioner filed a petition for review on certiorari assailing the decision of the
Court of Appeals.
ISSUE:
Whether or not the marriage between the parties is void ab initio on the ground of
both parties psychological incapacity, as provided in Article 36 of the Family Code
HELD:
The court granted the petition. The decision of the Court of Appeals in CA -G.R. CV
No. 89761 was reversed. The decision of the Regional Trial Court declaring the
marriage between petitioner and respondent null and void under Article 36 of the
Family Code was reinstated.
Respondents pattern of behavior manifests an inability, 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.
Even without the experts conclusions, the factual antecedents (narrative of events)
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.