Facts:

The case involves an appeal from the Decision dated 31 May 2007 of the Court of Appeals in CA-G.R. SP No. 00576, where the petitioners, May D. Aaonuevo, Alexander Blee DeSantis, and John DeSantis Neri, challenged the orders of the Regional Trial Court (RTC) of Negros Occidental that permitted their intervention in the intestate proceedings of the estate of Rodolfo G. Jalandoni. Rodolfo passed away intestate on 20 December 1966, without any issue. Bernardino G. Jalandoni, brother of Rodolfo, filed a petition for letters of administration on 28 April 1967, which became the basis of Spec. Proc. No. 338 in the intestate court. On 17 January 2003, the petitioners filed a Manifestation in court asserting their lineage from Sylvia Blee DeSantis, who was the daughter of Isabel Blee and John DeSantis. The petitioners contended that Isabel was Rodolfo's legal spouse at the time of his death, thereby granting them a claim to his estate. They argued for their right to intervene on behal

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Facts:

Background on the Estate

• Rodolfo G. Jalandoni died intestate on December 20, 1966, without issue.
• Bernardino G. Jalandoni, his brother, initiated proceedings by filing a petition for the issuance of letters of administration with the Court of First Instance of Negros Occidental, docketed as Spec. Proc. No. 338.

Petitioners’ Intervention and Evidence

• On January 17, 2003, the petitioners and their siblings submitted a Manifestation before the intestate court, seeking to intervene in the settlement proceedings.
• They claimed that Isabel Blee, their grandmother, was at the time of Rodolfo’s death the legal spouse of Rodolfo, thereby entitling them—by virtue of being her lawful representatives—to participate in the proceedings.
• To substantiate their claim, the petitioners attached key documents, which included:
• Two marriage certificates evidencing nuptials between Isabel and Rodolfo.
• Sylvia Blee Desantis’ birth certificate, which served to connect the petitioners to Isabel.
• The respective proofs of birth of the petitioners and their siblings.
• The central contention was that the evidence conclusively established Isabel’s status as Rodolfo’s legal spouse, thus granting her—and consequently her representatives—a right to a share in his estate.

Respondent’s Opposition and Counter-Evidence

• Represented by Bernardino, the respondent opposed the intervention on the ground that the petitioners failed to prove Isabel’s status as an heir of Rodolfo.
• The respondent pointed to the entries in Sylvia’s birth certificate, which indicated that Sylvia was a “legitimate” child of Isabel and John Desantis, and that Isabel and John Desantis were noted as “married.”
• This official record was argued to be prima facie evidence of a prior and subsisting marriage between Isabel and John Desantis.
• The implication was that Isabel’s subsequent marriage to Rodolfo was bigamous and void ab initio, thereby nullifying any interest she might have in Rodolfo’s estate.

Proceedings in the Lower Courts

• The Regional Trial Court (intestate court) allowed the petitioners and their siblings to intervene in the estate proceedings, basing its decision on the presented evidence, which it found sufficient to establish Isabel’s status as Rodolfo’s legal spouse.
• Even after the respondent’s opposition and request for reconsideration, the court maintained its ruling in orders dated July 2, 2004, and January 26, 2005.
• The respondent then elevated the issue by filing a petition for certiorari before the Court of Appeals.

Court of Appeals’ Decision

• On May 31, 2007, the Court of Appeals rendered a decision which nullified the lower court’s orders that allowed the intervention by the petitioners and their siblings.
• The appellate court’s decision was based on its assessment that:
• The evidence (most notably the birth certificate of Sylvia) affirmed that Isabel was already married to John Desantis at the time of her purported marriage to Rodolfo.
• In the absence of evidence proving the dissolution of Isabel’s prior marriage, her marriage to Rodolfo was considered bigamous and consequently void ab initio.
• The decision came with a permanent injunction against enforcing the assailed orders and was rendered without costs.

Issue:

Jurisdictional and Discretionary Concerns

• Whether the Regional Trial Court committed grave abuse of discretion by allowing the petitioners and their siblings—who lacked a bona fide interest in the litigation—to intervene in the estate proceedings.
• Whether the intervention, essentially a jurisdictional determination, was improperly granted given the absence of clear evidence establishing Isabel’s legal status as Rodolfo’s spouse.

Proper Evaluation of Evidentiary Value

• Whether the evidence presented by the petitioners (i.e., the two marriage certificates and related documents including Sylvia’s birth certificate) sufficiently establishes the marital relationship between Isabel and Rodolfo.
• Whether the entries in Sylvia’s birth certificate, which indicate Isabel’s marriage to John Desantis, should be given prima facie probative value in determining the validity of Isabel’s subsequent marriage to Rodolfo.
• Whether the Court of Appeals exceeded its proper limits of review by re-assessing the evidentiary record beyond a mere inquiry into grave abuse of discretion.

Impact on Inheritance Rights

• Whether Isabel can be considered the legal spouse of Rodolfo, thereby conferring on her (or her representatives) any interest in Rodolfo’s intestate estate.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)