Case Digest (G.R. No. 199199)
Facts:
In Alfelor v. Halasan, decided on March 31, 2006 under G.R. No. 165987, the heirs of the late Telesforo and Cecilia Alfelor filed a partition complaint in the Regional Trial Court (RTC) of Davao City on January 30, 1998, docketed as Civil Case No. 26,047-98. Among the plaintiffs were Teresita Sorongon Alfelor and her children Joshua S. Alfelor and Maria Katrina S. Alfelor, who claimed legitimacy as the surviving spouse and descendants of Jose K. Alfelor, one of Telesforo’s children. On October 20, 1998, Josefina M. Halasan, alleged to be the first and surviving spouse of Jose, moved to intervene, attaching an Answer in Intervention and a machine copy of her 1956 marriage contract to prove her marriage to Jose. She contended that the subsequent marriage between Jose and Teresita in 1966 was void ab initio due to the subsisting first marriage. At the RTC hearing, Teresita testified that, although she had learned of Josefina’s prior union only through acquaintances, she had contracCase Digest (G.R. No. 199199)
Facts:
- Filing of Partition Suit
- On January 30, 1998, the heirs of the late spouses Telesforo and Cecilia Alfelor filed Civil Case No. 26,047-98 for partition before the Regional Trial Court (RTC) of Davao City, Branch 17. Among the plaintiffs were Teresita Sorongon Alfelor and her two children, Joshua S. and Maria Katrina S. Alfelor, who claimed to be the surviving spouse and legitimate children of the late Jose K. Alfelor.
- On October 20, 1998, Josefina M. Halasan moved to intervene, alleging she was the surviving spouse and primary compulsory heir of Jose K. Alfelor, that she had received nothing from his share, and praying to submit an Answer in Intervention. She attached her marriage contract with Jose (February 1, 1956) and sought the appointment of a special administrator.
- Trial Court Proceedings and Orders
- Josefina failed to appear at the hearing; no witness identified or authenticated the alleged marriage contract. Teresita testified on February 13, 2002, regarding her own civil (February 12, 1966) and religious (April 30, 1966) marriages to Jose, her belief in good faith that Jose was unmarried, and her knowledge (from others) that Josefina had left Jose in 1959.
- On September 13, 2002, the RTC denied Josefina’s intervention for failure to prove her marriage, noting the uncertified copy of the contract and absence of testimony, and declared Teresita and her children as the legitimate heirs of Jose K. Alfelor. The RTC likewise denied her motion for reconsideration on October 30, 2002.
- Appellate Proceedings
- Josefina petitioned the Court of Appeals (CA) via Rule 65, alleging grave abuse of discretion by the RTC in dismissing her intervention despite proof of her marriage and the nullity of the second marriage under Articles 80 and 83 of the New Civil Code.
- On November 5, 2003, the CA reversed the RTC. Citing Section 4, Rule 129 of the Revised Rules of Court, it held that Teresita’s admissions in her pleading and testimony constituted judicial admissions obviating the need for proof. The CA ordered the RTC to admit Josefina’s intervention and proceed with the case.
- Joshua and Maria Katrina Alfelor filed a petition for review under Rule 45 in the Supreme Court, challenging only the CA’s order admitting Josefina’s intervention.
Issues:
- Did the Court of Appeals err in annulling the RTC’s orders and directing the admission of Josefina Halasan’s intervention in the partition case?
- Did Teresita’s statements qualify as judicial admissions that dispense with proof of Josefina’s marriage to Jose K. Alfelor?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)