G.R. No. 185286.
August 18, 2010 (Case Brief / Digest)
Title: Ma. Socorro Camacho-Reyes v. Ramon Reyes
### Facts
1. Initial Relationship (1972-1976):
– Petitioner Maria Socorro Camacho and respondent Ramon Reyes met in 1972 at the
University of the Philippines, Diliman.
– They developed a boyfriend-girlfriend relationship quickly. Petitioner admired respondent’s
free-spirited and unconventional ways.
– Despite discovering respondent’s marijuana use, this did not deter petitioner’s impression
of him. Petitioner finished her degree in AB Sociology, but respondent dropped out and
worked in the family business, the Aristocrat Restaurant.
2. Marriage and Early Challenges (1976-1989):
– In December 1976, petitioner, pregnant, married respondent. They lived with respondent’s
family in Mandaluyong City.
– Financial support from respondent diminished over time, with respondent leaving his job
and failing at multiple business ventures. Communication and connection between the
spouses eroded.
– Significant events like the birth of three children and a miscarriage, further strained their
relationship. Respondent’s indifferent behavior persisted through these trials.
3. Later Years and Estrangement (1996-2001):
– The relationship deteriorated further with respondent’s infidelity discovered in 1996 and
lack of concern during petitioner’s medical issues.
– Various efforts at counseling were unsuccessful. Respondent remained uncooperative.
– They separated around 1997 with respondent moving out.
4. Legal Proceedings:
– In 2001, petitioner filed a petition for nullity of marriage due to respondent’s psychological
incapacity under Article 36 of the Family Code.
– The RTC granted the petition after evaluating evidence from three expert testimonies
diagnosing respondent with personality disorders.
– Respondent’s motion for reconsideration was denied, and he appealed to the Court of
Appeals.
5. Court of Appeals Decision:
– The CA reversed the RTC’s decision, dismissing the petition for nullity citing insufficient
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G.R. No. 185286. August 18, 2010 (Case Brief / Digest)
evidence of psychological incapacity.
6. Supreme Court Petition:
– Petitioner appealed to the Supreme Court, contesting the CA’s ruling.
### Issues
1. Validity of Psychological Incapacity:
– Whether respondent Ramon Reyes was psychologically incapacitated to comply with marital
obligations.
2. Consideration of Expert Testimonies:
– Whether the CA erred in disregarding the expert testimonies of petitioner’s witnesses.
3. Factual Findings:
– Whether the CA disregarded the factual findings of the trial court.
4. Totality of Evidence:
– Whether the totality of the evidence presented established psychological incapacity by a
preponderance of evidence.
5. Effectiveness of Amended Petition:
– Whether the amended petition conformed to evidence presented and whether it validly
established psychological incapacity on the petitioner’s part as well.
### Court’s Decision
1. Psychological Incapacity of Respondent:
– The Supreme Court ruled that respondent’s behavior showed consistent irresponsibility and
failure to meet marital obligations, indicating psychological incapacity.
– The Court highlighted the persistent financial irresponsibility, substance abuse, infidelity,
and disengagement in family life as evidence.
2. Expert Testimonies:
– The Court found the CA erred in disregarding expert testimonies. Even without personal
examination, the experts’ assessments had sufficient basis from other credible sources
including family members and the petitioner.
– The Court accepted the diagnoses of personality disorders (Antisocial Personality Disorder
and associated traits), which were considered grave, juridically antecedent, and incurable.
3. Factual Findings of RTC:
– The Supreme Court emphasized the due deference typically given to the factual findings of
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G.R. No. 185286. August 18, 2010 (Case Brief / Digest)
the trial court, especially when supported by substantial evidence.
4. Incapacity on Part of Petitioner:
– The Court concurred with the CA that the petitioner’s psychological capacity was not
debilitating enough to void the marriage.
### Doctrine
1. Psychological Incapacity Under Article 36:
– Psychological incapacity must be a grave or serious mental condition that was existing at
the time of the marriage, although its symptoms may become evident later.
– It should be characterized by severity, juridical antecedence, and incurability, making a
person incapable of fulfilling the essential marital obligations.
2. Acceptance of Expert Testimonies:
– Courts may accept psychological assessments from expert witnesses even if the respondent
didn’t undergo personal evaluation, so long as the totality of evidence supports the diagnosis.
### Class Notes
– Legal Elements of Psychological Incapacity (Article 36, Family Code):
1. Gravity – Condition must be grave or serious.
2. Juridical Antecedence – Must exist at the time of marriage.
3. Incurability – Should be incurable or beyond the ability to cure.
– Relevant Statutes:
– Article 36, Family Code: Void marriages due to psychological incapacity.
– Article 68, Family Code: Marital obligations of love, respect, fidelity, and support.
### Historical Background
The case reflects the evolving understanding and application of “psychological incapacity”
within Philippine jurisprudence as grounds for declaring a marriage void under Article 36 of
the Family Code. It underscores the complexity of psychological evaluations in legal contexts
and the judiciary’s balancing act between upholding the sanctity of marriage and
acknowledging marital conditions that justify nullification.
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