Ting vs Ting

G.R. No. 166562

March 31, 2009

FACTS:
Benjamin Ting and Carmen Velez-Ting first met in 1972 while they were classmates in
medical school. They fell in love, and were wed on July 26, 1975 in Cebu City when
respondent was already pregnant with their first child. On October 21, 1993, after being
married for more than 18 years to petitioner, Carmen filed a verified petition before the
RTC of Cebu City praying for the declaration of nullity of their marriage based on Article 36
of the Family Code. She claimed that Benjamin suffered from psychological incapacity
even at the time of the celebration of their marriage, which, however, only became
manifest thereafter.

In his answer, Benjamin denied being psychologically incapacitated. RTC ruled in favor of
the respondent declaring the marriage null and void.

Petitioner appealed to the CA. CA reversed RTC’s decision. Respondent filed a motion for
reconsideration, arguing that the Molina guidelines (in relation to stare decisis) should not
be applied to this case

ISSUE:
Whether or not the CA violated the rule on stare decisis when it refused to follow the
guidelines set forth under the Santos and Molina cases.

HELD:
No. respondent’s argument that the doctrinal guidelines prescribed in Santos and Molina
should not be applied retroactively for being contrary to the principle of stare decisis is no
longer new. The interpretation and construction of a law by courts constitutes a part of the
law of the date the statute is enacted. It is only when a prior ruling of this Court is
overruled, and a different view is adopted, that the new doctrine may have to be applied
prospectively in favor of parties who have relied on the old doctrine and have acted in
good faith.