Case Digest (G.R. No. 191946) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Benjamin G. Ting v. Carmen M. Velez-Ting (G.R. No. 166562, March 31, 2009), petitioner Benjamin G. Ting and respondent Carmen M. Velez-Ting, both medical graduates, married on July 26, 1975 in Cebu City amid respondent’s pregnancy. They first lived with Benjamin’s family in Mandaue City before moving to Carmen’s home in Cebu. Benjamin pursued anesthesiology and joined Velez Hospital, where Carmen served as Treasurer. Over eighteen years, the couple bore six children. On October 21, 1993, Carmen filed before the Regional Trial Court (RTC), Branch 23, Cebu City, a petition to declare their marriage void ab initio under Article 36 of the Family Code on the ground of Benjamin’s alleged psychological incapacity. She detailed his chronic alcoholism, compulsive gambling, violent behavior, and refusal to provide financial support, supported by the testimony of their former nanny and psychiatrist Dr. Pureza Trinidad-OAate, who based her opinion on deposition transcripts. Benjamin coun Case Digest (G.R. No. 191946) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Benjamin G. Ting and Carmen Velez met as medical students in 1972 and married on July 26, 1975 in Cebu City; respondent was pregnant with their first child.
- The couple initially lived at Benjamin’s family home in Mandaue City, moving later to respondent’s family home in Cebu City.
- Careers and Roles
- Benjamin passed medical boards in September 1975, trained in anesthesiology (1975–1979), and joined Velez Hospital’s staff in 1980.
- Carmen served as Treasurer of Velez Hospital.
- Family
- They had six children: Dennis (b. Dec. 9, 1975), James Louis (b. Aug. 25, 1977), Agnes Irene (b. Apr. 5, 1981), Charles Laurence (b. July 21, 1986), Myles Vincent (b. July 19, 1988), Marie Corinne (b. June 16, 1991).
- Petition for Nullity (Oct. 21, 1993)
- Respondent sought declaration of nullity under Art. 36, alleging petitioner’s psychological incapacity manifested in chronic alcoholism, compulsive gambling, violence, neglect, and refusal of financial support.
- Allegations included late-night drunken returns, physical assaults, firearm misuse, pawning jewelry and property, and failure to support the family.
- Trial Evidence
- Respondent’s witnesses: Carmen (self-testimony), nanny Susana Wasawas (observed mistreatment), psychiatrist Dr. Pureza Trinidad-Oaate (opined personality disorder based on deposition transcript).
- Petitioner’s witnesses: Petitioner (denied incapacity), psychiatrist Dr. Renato Obra (opined no personality defect, based on deposition transcript, South Africa psychiatric report, interviews with petitioner’s brothers).
- Procedural History
- RTC (Jan. 9, 1998) declared marriage void ab initio under Art. 36.
- CA Decision (Oct. 19, 2000) reversed RTC; respondent moved for reconsideration; SC granted certiorari, remanding to CA.
- CA Amended Decision (Nov. 17, 2003) and Resolution (Dec. 13, 2004) affirmed nullity; petitioner filed present petition for review on certiorari.
Issues:
- Did the Court of Appeals violate stare decisis by refusing to apply the Santos and Molina guidelines?
- Did the Court of Appeals correctly apply the liberalized proof requirements for psychological incapacity under Article 36?
- Is the declaration of nullity of the marriage between petitioner and respondent in accordance with law and jurisprudence?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)