Case Digest (G.R. No. 187633) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 249011 decided on March 15, 2021, petitioners Cristita Anaban, Crispina Anaban, Pureza Anaban, Cresencia Anaban-Walang, and Rosita Anaban-Baristo (daughters of Pedrito Anaban by Pepang Guilabo) sought appellate relief from the Court of Appeals decision affirming their status as illegitimate children of the late Pedrito. Pedrito first married Virginia Erasmo in 1942 according to Ibaloi tribal customs and begot three children—Betty Anaban-Alfiler, Mercedes Anaban, and Marcelo Anaban (respondents). In 1947, the Ibaloi council of elders purportedly dissolved that marriage due to Virginia’s insanity, and in 1952 Pedrito wed Pepang Guilabo, siring eight children including the petitioners. Upon Pedrito’s death on September 2, 2004, respondents filed a summary settlement of his intestate estate, alleging Pedrito’s second marriage was bigamous because Philippine law did not recognize a tribal divorce, thus rendering petitioners illegitimate heirs. The Municipal Circuit Trial Case Digest (G.R. No. 187633) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Marriages and family relations
- In 1942, Pedrito Anaban married Virginia Erasmo under Ibaloi tribal customs and had three children (Betty, Mercedes, Marcelo).
- In 1947, the Ibaloi council of elders, noting Virginia’s insanity, purportedly granted a tribal divorce and allowed Pedrito to remarry.
- Subsequent marriage and offspring
- In 1952, Pedrito married Pepang Guilabo under the same tribal customs.
- They had eight children, including petitioners Cristita, Crispina, Pureza, Cresencia, and Rosita.
- Death of Pedrito and judicial proceedings
- Pedrito died in 2004; his first‐born children filed for summary partition of his intestate estate, naming the petitioners as respondents. They alleged the second marriage was bigamous.
- Petitioners contended both marriages and the tribal divorce were valid under Ibaloi customs, recognizing customary marriage dissolutions.
- Trial court (MCTC) ruled the tribal divorce valid, the second marriage legitimate, and all children legitimate heirs.
- On appeal, the Regional Trial Court declared the second marriage void for bigamy; petitioners were illegitimate heirs.
- The Court of Appeals affirmed the RTC, holding that non-Christian tribal customs do not validly dissolve marriage under applicable law.
- Petitioners filed this petition for review on certiorari to the Supreme Court.
Issues:
- Whether the divorce purportedly granted by the Ibaloi council of elders in 1947 dissolved the marriage of Pedrito and Virginia for purposes of Philippine law.
- Whether the subsequent marriage to Pepang Guilabo is valid and whether petitioners are legitimate heirs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)