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REYES V REYES

MA. SOCORRO CAMACHO-REYES, Petitioner,


vs.
RAMON REYES, Respondent.
GR no. 185286
August 18, 2010
Ponente: Nachura, J.

FACTS
Petitioner Maria Socorro Camacho-Reyes and Ramon Reyes got married on December 5, 1976 when the
petitioner was already five months pregnant. The couple lived with the respondent's parents who shouldered
their living expenses. At first, Ramon was giving Socorro a monthly allowance of P1,500 from his salary.
It was on March 22, 1997, the birth of their first child, when their financial difficulties started. The monthly
allowance stopped. Ramon resigned from his job in their family business and ventured into different business,
which all failed, brought a trail of debts and kept him away from his family. These events caused the parties'
relationship to deteriorate.
In 1996, Socorro found out Ramon's extra-marital affair and eventually, he failed to provide for the financial
needs as well as the fulfillment of his duties as a spouse and a father.
Petitioner tried to salvage the marriage by asking help from Ramon's siblings who invited them to counseling
sessions. Still, there was no improvement as Ramon was not cooperative. One of his siblings even brought
Ramon for a psychological assessment to "determine benchmarks of current psychological functioning."
Ramon resisted and did not go on with the psychotherapy. Socorro then asked Ramon to move out of their
house to which Ramon acquiesced.
The de facto separation did not improve the relationship and a petition for the declaration of nullity of her
marriage to Ramon was filed by Socorro before the RTC alleging the latter's psychological incapacity to fulfill
the essential marital obligations under Article 36 of the Family Code. The RTC granted the petition. However,
the CA reversed the said decision and granted Ramon's appeal, hence, this appeal to the Supreme Court.

ISSUE
WON the marriage between the parties is void ab initio under Article 36 of the Family Code

HELD
Yes. The Supreme Court reversed the CA's decision and reinstated the RTC's decision that the said marriage
is null and void under Article 36 of the Family Code.
Based on the evidence presented, with emphasis on the pervasive pattern of behaviors of the respondent and
outcome of the assessment/diagnosis of expert witnesses, Dra. Dayan, Dra. Mango and Dra. Villegas on the
psychological condition of the respondent, the Court finds that the marriage between the parties from its
inception has a congenital infirmity termed “psychological incapacity”. Dr. Dayan's recommendation that
respondent should undergo psychotherapy does not necessarily negate the incurability of his 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.