Post

Ma. Socorro Camacho-Reyes vs. Ramon Reyes

Posted
By Anonymous
8 min read
Ma. Socorro Camacho-Reyes vs. Ramon Reyes

Case Title and Citation

Ma. Socorro Camacho-Reyes, petitioner, vs. Ramon Reyes, respondent.
G.R. No. 185286, August 18, 2010
Supreme Court - Second Division
Ponente: Antonio Eduardo B. Nachura, J.

Facts

  • Petitioner Ma. Socorro Camacho-Reyes and respondent Ramon Reyes met in 1972 at the University of the Philippines, began a relationship, and married on December 5, 1976 while petitioner was pregnant.
  • The couple initially lived with respondent’s family in Mandaluyong City. Petitioner obtained an AB Sociology degree and worked; respondent dropped out of school and worked in the family business (Aristocrat Restaurant) before resigning to pursue various business ventures.
  • The first child was born on March 22, 1977. Financial difficulties ensued when respondent ceased giving petitioner his salary and the initial monthly allowance; respondent’s subsequent business ventures (seafood trading, fishponds, scrap trading) failed, leading to additional debts.
  • Respondent frequently left the family for extended periods for business, communicated poorly, and on multiple occasions showed indifference to petitioner and their children (including during petitioner’s surgery and after childbirth).
  • Petitioner discovered respondent’s extra-marital affair circa 1996 and observed continued substance use (marijuana), sporadic financial support, and alleged irresponsible conduct; respondent resisted counseling and psychological intervention.
  • In 1997 respondent was referred to Dr. Natividad A. Dayan for psychological assessment; respondent did not follow recommended psychotherapy.
  • Petitioner filed a petition for declaration of nullity of marriage in July 2001 (amended December 2001) alleging respondent’s psychological incapacity under Article 36 of the Family Code.
  • Trial produced testimony and reports from three expert witnesses: Dr. Natividad A. Dayan (clinical psychologist), Dr. Estrella T. T. Magno (clinical psychologist), and Dr. Cecilia C. Villegas (psychiatrist). Experts diagnosed respondent with personality disorder(s) (antisocial features, narcissistic, schizoid elements, mixed personality disorder) and described longstanding behavioral patterns.
  • The Regional Trial Court (Branch 89, Quezon City) granted the petition and declared the marriage null and void under Article 36, finding both parties exhibited psychological incapacity though placing primary emphasis on respondent.
  • On motion for reconsideration the RTC affirmed. The Court of Appeals, by decision of a special five-member division (with two dissenters), reversed the RTC and dismissed the petition, finding petitioner failed to prove respondent’s psychological incapacity and discounting some expert testimony for lack of personal examination of respondent.
  • Petitioner filed a petition for review on certiorari to the Supreme Court contesting the CA decision.

Issues

  1. Did the Court of Appeals err in not ruling that respondent is psychologically incapacitated to comply with the essential obligations of marriage?
  2. Did the Court of Appeals err in not ruling that petitioner is likewise psychologically incapacitated to comply with the essential obligations of marriage?
  3. Did the Court of Appeals err when it disregarded the testimonies of the expert witnesses presented by petitioner?
  4. Did the Court of Appeals err in not ruling that the findings of the trial court are binding on it?
  5. Did the Court of Appeals err in not ruling that the totality of the evidence presented duly established the psychological incapacities of the parties to comply with the essential obligations of marriage?
  6. Did the Court of Appeals err in not ruling that the psychological incapacities of the parties were established by a preponderance of evidence?
  7. Did the Court of Appeals err in not ruling that the parties’ marriage does not further State initiatives concerning marriage and family and therefore is not protected by constitutional recognition of the inviolability of marriage?
  8. Did the Court of Appeals err in not ruling that the amended petition was validly amended to conform to the evidence?

Ruling

  1. Yes - The Supreme Court found respondent psychologically incapacitated to comply with essential marital obligations and reinstated the RTC’s declaration of nullity under Article 36.
  2. No - The Court found petitioner’s alleged psychological incapacity not sufficiently pleaded or established to satisfy Article 36.
  3. Yes - The Court held that the CA erred in wholesale rejection of expert testimony; lack of a personal examination does not per se render experts’ assessments inadmissible or hearsay when based on multiple sources and observed behavior.
  4. Yes - The Court held the CA improperly substituted its judgment for the trial court on factual findings and expert credibility; the RTC findings warranted reinstatement.
  5. No/Yes - No as to both parties collectively; Yes as to respondent alone (the totality of evidence established respondent’s psychological incapacity, but the evidence did not establish petitioner’s incapacity).
  6. No/Yes - No as to both parties collectively; Yes as to respondent alone (the preponderance of evidence supported respondent’s incapacity under the Santos factors).
  7. No - The Court rejected the contention that constitutional protection of marriage precludes annulment where Article 36’s requisites are met; constitutional protection does not immunize invalid marriages from annulment when psychological incapacity is proven.
  8. Yes/No - Yes insofar as the amended petition supported adjudication of respondent’s incapacity; No insofar as petitioner did not properly allege or prove her own incapacity.

Reasoning / Ratio Decidendi

  • Statutory and jurisprudential framework:
    1. Article 36, Family Code provides for nullity of marriage when a party was psychologically incapacitated at the time of celebration to comply with essential marital obligations; Article 68 defines essential obligations (live together, mutual love, respect, fidelity, help and support).
    2. Santos v. Court of Appeals (G.R. No. 112019, January 4, 1995) articulated three non-exclusive requisites for Article 36: gravity (seriousness), juridical antecedence (rooted in premarital history), and incurability (or beyond the means of the party).
    3. Republic v. Court of Appeals & Molina and Lim v. Sta. Cruz-Lim supply guidance on evaluation of expert opinion and diagnostic criteria (reference to DSM IV).
  • Expert evidence:
    • The three experts (Drs. Dayan, Magno, Villegas) reached convergent diagnoses that respondent manifested a pervasive personality disorder (antisocial features, narcissistic, schizoid elements, mixed personality disorder) with long-standing patterns: chronic irresponsibility, poor impulse control, substance abuse, intermittent support, infidelity, failed ventures, unpaid obligations, and interpersonal detachment.
    • The Supreme Court held that experts may lawfully base their assessments on collateral information (petitioner’s firsthand observations, testimony of family members, documented history) and that lack of direct, prolonged personal examination does not automatically render their testimony inadmissible or hearsay.
    • The Court rejected the CA’s reasoning that Dr. Dayan’s recommendation for therapy negated incurability; a recommendation for therapy does not ipso facto establish curability because therapy may manage behavior without curing an ingrained personality disorder.
  • Application of Santos factors:
    • Gravity: Respondent’s behaviors were found sufficiently grave to amount to incapacity to perform essential marital obligations.
    • Juridical antecedence: Expert reports and collateral history traced respondent’s pattern starting in adolescence/early adulthood (conduct disorder, long-term substance use), satisfying antecedence.
    • Incurability: Experts described the disorder as stable, long-standing, and engrained; therapy recommendations did not demonstrate curability within means.
  • Pleading and proof for petitioner:
    • The Court agreed with the CA that petitioner failed to specifically allege complete facts showing her own psychological incapacity at the time of marriage, and expert findings regarding petitioner described personality style not amounting to Article 36 incapacity.
  • Constitutional consideration:
    • The sanctity and inviolability of marriage is a constitutional value but does not preclude annulment when statutorily defined psychological incapacity is satisfactorily proven; doubts are resolved in favor of preserving marriage, but where the Santos requisites are met, nullity follows.

Doctrine / Legal Principle

  • Article 36 (Family Code) requires proof of psychological incapacity that is grave, rooted antecedently to the marriage, and incurable (Santos test).
  • Expert psychological and psychiatric testimony admissible and may be based on collateral information; lack of direct interview does not automatically render such testimony hearsay.
  • A recommendation for therapy does not by itself establish curability of a diagnosed personality disorder.
  • Constitutional protection of marriage does not bar annulment under Article 36 when its requisites are proven.

Disposition

  • Petition for review on certiorari granted.
  • The decision of the Court of Appeals in CA-G.R. CV No. 89761 is REVERSED.
  • The decision of the Regional Trial Court, Branch 89, Quezon City in Civil Case No. Q-01-44854 declaring the marriage between Ma. Socorro Camacho-Reyes and Ramon Reyes NULL and VOID under Article 36 of the Family Code is REINSTATED.

  • No costs.

  • Effect: Marriage declared void ab initio as to respondent’s psychological incapacity; parties restored to single status and property relations to be dealt with per RTC directive and applicable rules referenced in the RTC decision.

Concurring / Dissenting Opinions

  • No separate concurring or dissenting opinions in the Supreme Court decision; the opinion was rendered by Justice Nachura and the Court’s concurrence is indicated.

Significance / Notes

  • Reaffirms Santos v. Court of Appeals three-factor test (gravity, juridical antecedence, incurability) as the controlling standard for Article 36 annulment claims.
  • Clarifies evidentiary treatment of expert testimony in psychological incapacity cases: experts may rely on collateral sources and observed marital behavior; courts should evaluate the totality and consistency of expert reports rather than exclude opinions solely because the expert did not personally examine the alleged incapacitated party at length.
  • Emphasizes that therapy recommendations do not conclusively establish curability; courts must assess permanence and pervasiveness of the disorder.
  • Stresses careful judicial inquiry: courts must be cautious before finding psychological incapacity and avoid vicarious or speculative diagnoses, but must also not uphold marriages that are void where statutory requisites are satisfied.
  • Procedural reminder: allegations of a party’s own psychological incapacity must be specifically pleaded and proved; amendment to conform to evidence must be considered in context of what was asserted and proved.
  • Cites controlling authorities used in analysis: Santos v. Court of Appeals (G.R. No. 112019), Republic v. Court of Appeals & Molina, Lim v. Sta. Cruz-Lim, and DSM IV diagnostic criteria as referenced.
Persons and Family Relations Judicial Review
This post is licensed under CC BY 4.0 by the author.