Camacho-Reyes v. Reyes, G.R. No. 185286, Aug. 18, 2010

FACTS: Petitioner Maria Socorro Camacho-Reyes met respondent Ramon Reyes at the UP Diliman, in 1972 when they were both 19 years old. Petitioner enjoyed respondent’s style of courtship which included dining out, unlike other couples their age who were restricted by a university student’s budget. At that time, respondent held a job in the family business, the Aristocrat Restaurant. Petitioner’s good impression of the respondent was not diminished by the latter’s habit of cutting classes, not even by her discovery that respondent was taking marijuana. On December 5, 1976, petitioner and respondent got married. They lived with Ramon’s parents and they were supported by them. They had a child which made their financial difficulties worse. All the business ventures of Ramon were unsuccessful and Socorro became the breadwinner of the family. To make things worse, despite the fact that Socorro would undergo an operation for removal of a cyst, respondent remained unconcerned and unattentive; and simply read the newspaper, and played dumb when petitioner requested that he accompany her as she was wheeled into the operating room. They tried to attend counseling sessions but nothing has changed. Sometime in 1996, petitioner confirmed that respondent was having an extra-marital affair. RTC granted the petition. CA reversed. Hence, this petition.

ISSUE: W/N Ramon is psychologically incapacitated

HELD: Yes. Marriage is null and void. 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. In the instant case, 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.