Camacho-Reyes v. Reyes
Camacho-Reyes v. Reyes
Camacho-Reyes v. Reyes
SO ORDERED.
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* SECOND DIVISION.
462
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463
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464
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NACHURA, J.:
This case is, again, an instance of the all-too-familiar
tale of a marriage in disarray.
In this regard, we air the caveat that courts should be
extra careful before making a finding of psychological
incapacity or vicariously diagnosing personality disorders
in spouses where there are none. On the other hand, blind
adherence by the courts to the exhortation in the
Constitution1 and in our statutes that marriage is an
inviolable social institution, and validating a marriage that
is null and void despite convincing proof of psychological
incapacity, trenches on the very reason why a marriage
that is doomed from its inception should not be forcibly
inflicted upon its hapless partners for life.
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465
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466
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5 The original petition was filed in July of 2001; RTC records, pp. 1-18;
the amended petition, in December of the same year, id., at pp. 87-88.
469
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470
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471
I
THE COURT OF APPEALS ERRED IN NOT RULING THAT
RESPONDENT IS PSYCHOLOGICALLY INCAPACITATED TO
COMPLY WITH THE ESSENTIAL OBLIGATIONS OF
MARRIAGE.
II
THE COURT OF APPEALS ERRED IN NOT RULING THAT
PETITIONER IS LIKEWISE PSYCHOLOGICALLY
INCAPACITATED TO COMPLY WITH THE ESSENTIAL
OBLIGATIONS OF MARRIAGE.
III
THE COURT OF APPEALS ERRED WHEN IT DISREGARDED
THE TESTIMONIES OF THE EXPERT WITNESSES
PRESENTED BY PETITIONER.
IV
THE COURT OF APPEALS ERRED IN NOT RULING THAT
THE FINDINGS OF THE TRIAL COURT ARE BINDING ON IT.
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V
THE COURT OF APPEALS ERRED 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.
VI
THE COURT OF APPEALS ERRED IN NOT RULING THAT
THE PSYCHOLOGICAL INCAPACITIES OF THE PARTIES TO
COMPLY WITH THE ESSENTIAL OBLIGATIONS OF
MARRIAGE WERE ESTABLISHED, NOT MERELY BY A
TOTALITY, BUT BY A PREPONDERANCE OF EVIDENCE.
VII
THE COURT OF APPEALS ERRED IN NOT RULING THAT
THE PARTIES’ MARRIAGE, WHICH IS UNDOUBTEDLY VOID
AB INITIO UNDER ARTICLE 36 OF THE FAMILY CODE,
DOES NOT FURTHER THE INITIATIVES OF THE STATE
CONCERNING
472
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473
474
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475
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476
477
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478
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479
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480
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support of his wife regarding his decision to go into his own business. But
when he failed, the more he became negativistic and closed to
suggestions especially from [petitioner]. He was too careful not to let go
or make known his strong sense of inadequacy,
481
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482
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483
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484
_______________
485
486
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487
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488
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489
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490
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491
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492
“It was folly for the trial court to accept the findings and
conclusions of Dr. Villegas with nary a link drawn between the
“psychodynamics of the case” and the factors characterizing the
psychological incapacity. Dr. Villegas’ sparse testimony does not
lead to the inevitable conclusion that the parties were
psychologically incapacitated to comply with the essential marital
obligations. Even on questioning from the trial court, Dr. Villegas’
testimony did not illuminate on the parties’ alleged personality
disorders and their incapacitating effect on their marriage x x x.
Curiously, Dr. Villegas’ global conclusion of both parties’
personality disorders was not supported by psychological tests
properly administered by clinical psychologists specifically
trained in the tests’ use and interpretation. The supposed
personality disorders of the parties, considering that such
diagnoses were made, could have been fully established by
psychometric and neurological tests which are designed to
measure specific aspects of people’s intelligence, thinking, or
personality.
xxxx
The expert opinion of a psychiatrist arrived at after a
maximum of seven (7) hours of interview, and unsupported by
separate psychological tests, cannot tie the hands of the trial
court and prevent it from making its own factual finding on what
happened in this case. The probative force of the testimony of an
expert does not lie in a mere statement of his theory or opinion,
but rather in the assistance that he can render to the courts in
showing the facts that serve as a basis for his criterion and the
reasons upon which the logic of his conclusion is founded.”
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“Art. 68. The husband and wife are obliged to live together,
observe mutual love, respect and fidelity, and render mutual help
and support.”
493
celebration x x x. In fact, what was merely prayed for in the said
Amended Petition is that judgment be rendered “declaring the
marriage between
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494
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29 Rollo, p. 43.
30 Supra note 23, at p. 214.
465
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