Case Digest (G.R. No. 185374) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Simplicia Cercado-Siga and Ligaya Cercado-Belison v. Vicente Cercado, Jr. et al., petitioners Simplicia Cercado-Siga and Ligaya Cercado-Belison claimed to be the legitimate daughters of the late Vicente Cercado, Sr. and his first wife, Benita Castillo, whom they alleged were validly married on October 9, 1929 in Pililla, Rizal. During their parents’ lifetimes, Vicente Sr. acquired a 6,032 sq. m. parcel of land in Barangay Kinagatan, Binangonan, Rizal, now covered by Tax Declaration No. BIP-021-0253. Upon learning through a 1998 newspaper notice that respondents—Vicente Cercado, Jr., Manuela C. Arabit, Lolita C. Basco, Maria C. Aralar, and Violeta C. Binadas—had executed an Extrajudicial Settlement of Estate of Vicente Sr. with a certain Leonora C. Arabit (to whom Vicente Sr. allegedly married on June 27, 1977), petitioners filed a complaint to annul the settlement, correct the marital status of Vicente Sr. and Leonora, and recover their intestate shares. Petitioners offered a Case Digest (G.R. No. 185374) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Controversy
- Petitioners Simplicia Cercado-Siga and Ligaya Cercado-Belison claim to be the legitimate daughters of Vicente Cercado, Sr. and Benita Castillo, who were married on 9 October 1929 in Pililla, Rizal. Their father acquired by gratuitous title a 6,032-sqm parcel in Binangonan, Rizal. Upon his death, petitioners assert their right to inherit as legitimate heirs and to succeed to Benita’s share.
- In September 1998, petitioners discovered an Extrajudicial Settlement of Estate executed by respondents as heirs of Vicente and a certain Leonora Ditablan, whom respondents claim married Vicente in 1977. Petitioners filed a complaint to nullify that Deed, to correct the Register of Deeds entry on Vicente’s marital status, and for damages and attorney’s fees.
- Evidence Adduced
- To prove the 1929 marriage: (a) Contrato Matrimonial from the Iglesia Filipina Independiente; (b) church certification of acceptance; (c) certifications of non-production of birth records (Pililla, Rizal); (d) baptismal certificates of petitioners; (e) joint affidavit of two disinterested persons.
- Respondents countered that: (a) petitioners failed to present birth certificates; (b) the Contrato Matrimonial is not a certified true copy; (c) the baptismal certificate does not prove kinship; (d) the joint affidavit is hearsay; and (e) petitioners are estopped by laches.
- Procedural History
- Regional Trial Court (30 January 2007): Declared the Extrajudicial Settlement null and void for depriving Benita of her conjugal share and petitioners of their legitimes; allotted undivided shares; awarded P30,000 attorney’s fees and costs.
- Court of Appeals (5 August 2008 Decision; 14 November 2008 Resolution): Reversed the RTC, ruling petitioners failed to prove the first marriage—holding the Contrato Matrimonial a private, unauthenticated document; baptismal certificate inconclusive; joint affidavit hearsay. Motion for reconsideration denied. Petitioners elevated the case to the Supreme Court.
Issues:
- Whether the Contrato Matrimonial is admissible and sufficient to prove the marriage of Vicente and Benita as a public or as an ancient document.
- Whether petitioners proved filiation and marriage by baptismal certificates, certifications of non-production of civil records, and the joint affidavit.
- Whether the subsequent marriage of Vicente to Leonora is bigamous and can be collaterally attacked.
- Whether absence of proof of the first marriage renders the Extrajudicial Settlement valid.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)