Facts:

In the case of Joshua S. Alfelor and Maria Katrina S. Alfelor vs. Josefina M. Halasan and the Court of Appeals (G.R. No. 165987, March 31, 2006), the controversy revolves around the claim of ownership over the estate of the late Jose K. Alfelor. On January 30, 1998, a complaint for partition was filed by the children and heirs of Telesforo and Cecilia Alfelor before the Regional Trial Court (RTC) in Davao City. Among the plaintiffs were Teresita Sorongon and her two children, who asserted their rights as heirs of Jose K. Alfelor, the son of Telesforo and Cecilia, who had passed away. On October 20, 1998, Josefina H. Halasan, the respondent, filed a Motion for Intervention, claiming to be the legal spouse of Jose K. Alfelor and alleging that Teresita's subsequent marriage to Jose was void ab initio, as it occurred during the subsistence of her marriage to him. Josefina provided evidence of her marriage to Jose, which took place on February 1, 1956.

Despite her assertions, Jos

...

Facts:

Initiation of the Partition Case

• On January 30, 1998, the children and heirs of the late spouses Telesforo and Cecilia Alfelor filed a Complaint for Partition before the RTC of Davao City (Civil Case No. 26,047-98).
• Among the plaintiffs were Teresita Sorongon and her two children, Joshua S. Alfelor and Maria Katrina S. Alfelor, who claimed to be the surviving spouse and legal heirs, respectively, of Jose Alfelor, one of the children of the deceased.

Filing of the Motion for Intervention by Josefina Halasan

• On October 20, 1998, respondent Josefina H. Halasan filed a Motion for Intervention, asserting that she:
• Had a legal interest in the partition litigation as the surviving spouse and primary compulsory heir of Jose K. Alfelor.
• Had not received any share of the intestate estate of Telesforo Alfelor.
• To support her claim, Josefina attached a machine copy of a marriage contract showing that she and the decedent were married on February 1, 1956, and submitted an Answer in Intervention, in which she claimed that the subsequent marriage of Teresita was void ab initio and her alleged children with Jose were not his.

Testimonies and Evidence at the RTC

• Teresita Sorongon testified before the RTC on February 13, 2002, stating:
• That she and Jose were married in civil rites on February 12, 1966, in Tagum City and later in religious rites on April 30, 1966, at the Assumption Church.
• That she was aware of a previous marriage between Jose and Josefina and that Josefina had abandoned Jose years earlier.
• Evidence presented included:
• Josefina’s submission of the marriage contract (as a machine copy) and her Answer in Intervention.
• Teresita’s admission in her Reply in Intervention, in which she acknowledged knowledge of the decedent’s previous marriage to Josefina.

Decision of the Regional Trial Court (RTC)

• On September 13, 2002, Judge Renato A. Fuentes issued an Order:
• Denying Josefina’s motion to intervene and dismissing her complaint for lack of evidence.
• Emphasizing that the intervenor failed to appear in court to personally testify or produce an original copy of the marriage contract.
• Relying on the principle that Teresita’s good faith in contracting her marriage with Jose, despite acknowledgment of a prior marriage, was determinative.
• Citing Sarmiento v. Court of Appeals for the insufficiency of a machine copy without proper identification or accompanying formalities.

Subsequent Motions and Appellate Proceedings

• Josefina filed a Motion for Reconsideration, arguing:
• That under Section 4, Rule 129 of the Revised Rules of Court, a judicial admission need not be proved.
• That Teresita’s earlier statements admitting knowledge of the previous marriage should have been conclusive.
• The RTC denied the motion for reconsideration in its October 30, 2002 Order.
• Josefina then filed a Petition for Certiorari under Rule 65 before the Court of Appeals (CA), alleging grave abuse of discretion by the RTC in dismissing her intervention.
• The CA, in its Decision dated November 5, 2003, reversed the RTC:
• Holding that the judicial admission made by Teresita in her pleadings (and subsequent testimony) was conclusive.
• Ruling that no further evidence was required to establish Josefina’s claim as the prevailing judicial admission under Section 4, Rule 129 of the Revised Rules of Evidence.
• Ordering the RTC to admit Josefina’s complaint-in-intervention and to continue with the proper proceedings.

Petition for Review on Certiorari

• Joshua and Maria Katrina Alfelor (petitioners) filed the instant petition, challenging the CA’s ruling.
• They limited the issue to whether the CA erred in allowing Josefina’s intervention, arguing that:
• The CA disregarded the hearsay rule by accepting Teresita’s admission.
• Such judicial admissions should be subject to contradiction if made by palpable mistake.
• The petitioner’s contention also involved the inconsistencies in Teresita’s statements and a questioning of Josefina’s legal interest given her prolonged absence and failure to substantiate her claim beyond a machine copy of the marriage contract.

Issue:

• Whether the judicial admission by Teresita, acknowledging the previous marriage of the decedent to Josefina, was conclusive and sufficient under Section 4, Rule 129 of the Revised Rules of Evidence, thereby negating the need for additional proof.
• Whether the trial court erred in dismissing Josefina’s motion for intervention based on the insufficiency of her evidentiary submissions and absence from court.
• Whether the CA correctly determined that Josefina, having demonstrated a legal interest in the partition case, was entitled to intervene as a party, despite the petitioners’ objections regarding hearsay and evidentiary rules.
• Whether the petitioner’s contention that accepting judicial admissions conflicts with the hearsay rule holds merit, particularly in the context that such admissions are a complete waiver of proof for the matters admitted.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)