The movie has atmosphere, & a good soundtrack, but overall suffers from an overly simplistic plot & lack of layered subplots. There are some metaphors & allegories that only become apparent at the end.
There is overacting on the part of the lead character, & he's a little TOO "nice", like wimpy nice. This might be because he is meant to be childlike for plot reasons, but he still comes across as too "nice" & fragile.
The scariest entity in the film turns out to be not the Owlman, but eventually Evie, the woman. Having said that, my favourite parts of the film are the dance scenes by Evie, which show her at her most seductive. She's a great dancer & poser. The first dance scene reminded me a bit of Brit Ekland's dance scene in the Wicker Man (minus the nudity). The dance scenes are almost like they're from a completely different movie.
I found parts of the plot implausible or unrealistic. Like if the mother really didn't want her son to go to the old mansion, then why on earth would she will the property to him? Just sell the thing beforehand & include the money in the estate. And the protagonist's running commentary into a dictation device is unnecessary & silly as well.
The Owlman's voice is over-drenched in reverb. More subtle use of that effect would be less distracting.
However, overall I appreciate that Lord of Tears is not a slash/gore/gratuitous violence kind of horror film, rather it relies on more subtle suspense & emotional & cerebral elements. But it's not on par with a movie like The Orphanage, which the Lord of Tears director refers to in a promo for Lord of Tears.