G.R. NO.

185286, August 18, 2010

SOCORRO CAMACHO-REYES, vs. RAMON REYES,

FACTS:

Marital difficulties, which mostly is due to the respondent’s actions, caused the petitioner to file a
petition for declaration of nullity of her marriage with the respondent alleging psychological incapacity
to fulfill the essential marital obligations under Article 36 of the Family Code.

Traversing the petition, respondent denied petitioner’s allegations that he was psychologically
incapacitated. Respondent maintained that he was not remiss in performing his obligations to his
family—both as a spouse to petitioner and father to their children.

[Petitioner] presented several expert witnesses to show that [respondent] is psychologically

incapacitated. Clinical psychologist Dayan diagnosed [respondent] as purportedly suffering from Mixed
Personality Disorder (Schizoid Narcissistic and Anti-Social Personality Disorder). Further, clinical
psychologist Magno found [respondent] to be suffering from an Antisocial Personality Disorder with
narcissistic and dependent features, while Dr. Villegas diagnosed [respondent] to be suffering from
Personality Disorder of the anti-social type, associated with strong sense of Inadequacy especially along
masculine strivings and narcissistic features.

The RTC granted the petition and declared the marriage between the parties null and void on the
ground of their psychological incapacity.

The respondent appealed to the Court of Appeals. The appellate court reversed the RTC decision and
declared the parties’ marriage valid and subsisting. It held that the petitioner failed to sufficiently
establish the alleged psychological incapacity of her husband, as well as of herself. It held:

“In the case at bar, we hold that the court a quo’s findings regarding the [respondent’s] alleged mixed
personality disorder, his “come and go” attitude, failed business ventures, inadequate/delayed financial
support to his family, sexual infidelity, insensitivity to [petitioner’s] feelings, irresponsibility, failure to
consult [petitioner] on his business pursuits, unfulfilled promises, failure to pay debts in connection with
his failed business activities, taking of drugs, etc. are not rooted on some debilitating psychological
condition but on serious marital difficulties/differences and mere refusal or unwillingness to assume the
essential obligations of marriage. [Respondent’s] “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 xxx. In fact, [petitioner] admitted in her Amended Petition that initially they lived
comfortably and [respondent] would give his salary in keeping with the tradition in most Filipino
households, but the situation changed when [respondent] resigned from the family-owned Aristocrat
Restaurant and thereafter, [respondent] failed in his business ventures. It appears, however, that
[respondent] has been gainfully employed with Marigold Corporation, Inc. since 1998, which fact was
stipulated upon by the [petitioner].”

ISSUE: Whether or not the Court of Appeals was correct when it rejected the testimonies of Doctors
Magno and Villega
RULING: NO. The Supreme Court held. Notwithstanding these telling assessments, the CA
rejected, wholesale, the testimonies of Doctors Magno and Villegas for being hearsay since they never
personally examined and interviewed the respondent.

We do not agree with the CA.

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.

For one, marriage, by its very definition, 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. In this case, the experts testified on their individual assessment of the present state
of the parties’ marriage from the perception of one of the parties, herein petitioner. Certainly,
petitioner, during their marriage, had occasion to interact with, and experience, respondent’s pattern of
behavior which she could then validly relay to the clinical psychologists and the psychiatrist.

For another, the clinical psychologists’ and psychiatrist’s assessment were not based solely on the
narration or personal interview of the petitioner. Other informants such as respondent’s own son,
siblings and in-laws, and sister-in-law (sister of petitioner), testified on their own observations of
respondent’s behavior and interactions with them, spanning the period of time they knew him. These
were also used as the basis of the doctors’ assessments.

Within their acknowledged field of expertise, 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 of the doctors’ separate diagnoses, does not necessarily evoke credence and
cannot trump the clinical findings of experts.

In sum, 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 psychologist’s or psychiatrist’s 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
psychologist’s or psychiatrist’s finding of a personality disorder does not exclude a finding that a
marriage is valid and subsisting, and not beset by one of the parties’ or both parties’ psychological
incapacity.

In the case at bar, however, 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.

The respondent’s pattern of 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.