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BENJAMIN G. TING v. CARMEN M. VELEZ-TING

FACTS:

In 1993, Carmen filed a petition for the declaration of nullity of her marriage with Benjamin based on Article 36 of the Family Code, alleging that Benjamin suffered from psychological incapacity. She claimed that Benjamin had a drinking and gambling problem, would come home drunk and violent, and physically assault her. Carmen's testimony was supported by their children's nanny who witnessed Benjamin's behavior. The trial court granted Carmen's petition, but the Court of Appeals reversed the decision, stating that there was no proof of Benjamin's psychological incapacity. Carmen filed a motion for reconsideration, arguing that the guidelines set forth in Santos v. Court of Appeals and Rep. of the Phils. v. Court of Appeals and Molina should not be retroactively applied to her case. The CA eventually reversed its previous ruling and upheld the trial court's decision. Benjamin filed a petition with the Supreme Court, raising issues on stare decisis, the liberalization of proof of psychological incapacity, and the correctness of the CA's decision. The Supreme Court found merit in the petition and discussed each of the issues.

This case involves the application of the "res judicata" doctrine. The parties had previously litigated a similar issue, and the doctrine was raised as a defense. However, the court recognized that res judicata may not be followed if it would be plainly unreasonable or inequitable to do so. The court aimed to determine if the previous litigation was conducted fairly and judiciously and if applying the doctrine in this case would result in an unjust outcome.

ISSUES:

  1. Whether the principle of stare decisis applies in the Philippine legal system.

  2. Whether there are exceptions to the application of stare decisis.

  3. Whether the doctrine of stare decisis should be applied in constitutional litigations

  4. Whether the Molina doctrine on the proof required for the declaration of nullity of marriage under Article 36 has been abandoned

  5. Whether the expert opinions of psychiatrists tracing the root cause, gravity, and incurability of a party's alleged psychological incapacity should be weighed by the court in deciding whether to grant a petition for nullity of marriage.

  6. Whether the evidence presented by respondent is sufficient to prove petitioner's psychological incapacity as of the date of the marriage.

RULING:

  1. Yes, the principle of stare decisis applies in the Philippine legal system. It is based on the principle that once a question of law has been examined and decided, it should be deemed settled and closed to further argument. It is entrenched in Article 8 of the Civil Code. The principle migrated from the English courts to the United States and was recognized by the framers of the U.S. Constitution.

  2. There are exceptions to the application of stare decisis. Courts may refuse to be bound by stare decisis when its application perpetuates illegitimate and unconstitutional holdings, when it cannot accommodate changing social and political understandings, when it leaves the power to overturn bad constitutional law solely in the hands of Congress, and when activist judges can dictate the policy for future courts while judges that respect stare decisis are stuck agreeing with them.

  3. The court held that the doctrine of stare decisis should not be applied rigidly in constitutional litigations in order to promote public welfare. The court cited previous cases where it reversed its original rulings in order to correct constitutional errors or promote justice and fairness.

  4. The court clarified that the Molina doctrine has not been abandoned, but rather, relaxed. The court recognized that the rigid set of rules set forth in Molina became a straightjacket for cases involving psychological incapacity. The court emphasized that each case should be treated distinctly and judged based on its own attendant facts. The court also stated that while expert opinions on psychological incapacity are highly advisable, they are not indispensable evidence and the totality of evidence presented should be considered in deciding the case.

  5. Yes, expert opinions of psychiatrists tracing the root cause, gravity, and incurability of a party's alleged psychological incapacity should be weighed by the court in deciding whether to grant a petition for nullity of marriage.

  6. No, the evidence presented by respondent is insufficient to prove petitioner's psychological incapacity as of the date of the marriage.

PRINCIPLES:

  • Stare decisis: The principle of adhering to the precedents established by higher courts.

  • Vertical stare decisis: The duty of lower courts to apply the decisions of higher courts to cases involving the same facts.

  • Horizontal stare decisis: The requirement that high courts must follow their own precedents.

  • Constitutional stare decisis: The binding effect of the doctrine in constitutional litigations. Courts have more flexibility in refusing to apply stare decisis in constitutional cases.

  • Statutory stare decisis: The binding effect of the doctrine in cases involving the interpretation of statutes. Courts have less flexibility in refusing to apply stare decisis in statutory cases.

  • Reasons for following stare decisis: Legitimization of judicial institutions, promotion of judicial economy, and predictability.

  • Exceptions to the application of stare decisis: Application perpetuating illegitimate and unconstitutional holdings, inability to accommodate changing social and political understandings, leaving the power to overturn bad constitutional law solely in the hands of Congress, and the potential dominance of activist judges.

  • Stare decisis may be set aside in constitutional litigations to correct constitutional errors or promote justice and fairness.

  • The Molina doctrine on the proof required for the declaration of nullity of marriage under Article 36 has been relaxed, allowing for a case-to-case basis approach. Expert opinions on psychological incapacity are not indispensable evidence, and the totality of evidence should be considered.

  • The intendment of the law is to confine the application of Article 36 to the most serious cases of personality disorders demonstrative of an utter insensitivity or inability to give meaning and significance to the marriage.

  • The psychological illness that must have afflicted a party at the inception of the marriage should be a malady so grave and permanent as to deprive one of awareness of the duties and responsibilities of the matrimonial bond.

  • The presumption is always in favor of the validity of marriage.