Ma. Socorro Camacho-Reyes v. Ramon Reyes-Reyes

Summary

This Supreme Court case involved a petition for declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code. After 21 years of marriage marked by the husband's pattern of financial irresponsibility, substance abuse, infidelity, and emotional neglect, the wife sought nullity. The RTC granted the petition based on expert testimony diagnosing the husband with antisocial personality disorder. The Court of Appeals reversed, finding insufficient evidence and emphasizing marriage sanctity. The Supreme Court reinstated the RTC decision, clarifying that expert testimony need not be based solely on personal examination and that the totality of evidence established the husband's psychological incapacity under the three-factor test of gravity, juridical antecedence, and incurability. The case reinforces standards for psychological incapacity determinations while rejecting overly restrictive evidentiary requirements.