Camacho-Reyes vs.

Reyes
Civil Law; Marriage; Psychological incapacity

A petition for review on certiorari attacking the decision of the Court of Appeals reversing the
decision of the Regional Trial Court of Quezon City nullifying the marriage between the
petitioner Camacho and respondent Reyes on the ground of psychological incapacity.

Facts: Petitioner and respondent were campus sweethearts. The former’s love to the latter did
not change even when she discovered that respondent was cutting classes and taking up
marijuana. He did not even finish college. By the time they married each other, all living
expenses were shouldered by respondent’s parents, and they were living with the respondent’s
parents. When their first child was born, financial difficulties started to come in. To prod
respondent into assuming more responsibility, petitioner suggested that they live separately from
her in-laws. However, the new living arrangement engendered further financial difficulty.
Petitioner was a single-income earner, and the business ventures of the respondent all
floundered. The couple became so estranged from each other that the respondent remained
unconcerned and inattentive, not only to the petitioner but also to their children. To make things
worse, petitioner was able to confirm that respondent was having an extra-marital affair.

Issue: Whether or not the respondent is psychologically incapacitated to fulfill the essential
marital obligations under Article 36 of the Family Code.

Ruling: Yes, there existed psychological incapacity. The marriage between the petitioner and the
respondent was nullified.

Psychological incapacity was shown by respondent’s 1.) sporadic financial support; 2.) extra-
marital affairs; 3.) substance abuse; and 4.) failed business attempts. The high court found that
the marriage between the parties from its inception had this “congenital infirmity” which
“pertains to the inability of the parties to effectively function emotionally, intellectually and
socially towards each other in relation to their essential duties to mutually observe love, fidelity
and respect as well as to mutually render help and support” as mandated by Article 68 of the
Family Code. Such finding was anchored by the unanimous findings of three psychology
experts: petitioner manifested inadequacies along her affective sphere that made her less
responsive to the emotional needs of her husband, while the respondent manifested “strong sense
of Inadequacy along masculine strivings and narcissistic features that renders him
psychologically incapacitated to perform the duties and responsibilities of marriage.” The
Supreme Court further ruled that such psychological incapacity, as stated by psychology experts,
is permanent, incurable, and stable over time, and mere recommendation of one psychology
expert that the incapacity is curable does not automatically imply curability. Therefore, the case
has the gravity, juridical antecedence, and incurability – the three requirements of nullifying
marriage based on psychological incapacity.