G.R. No. L-31156 - Pepsi-Cola Bottling Co. of the Philippines, Inc. vs. Municipality of Tanauan

Orlando B. Catalan, a naturalized American citizen, allegedly obtained a divorce in the United States from his first wife, Felicitas Amor.
After the divorce, he contracted a second marriage with petitioner Merope Enriquez Vda. de Catalan.
Orlando died intestate on November 18, 2004, in the Philippines.

Petitioner filed a Petition for the issuance of letters of administration with the Regional Trial Court (RTC) of Dagupan City on February 28, 2005, to be appointed administratrix of Orlando’s intestate estate (Special Proceedings No. 228).
Respondent Louella A. Catalan-Lee, daughter of Orlando from his first marriage, filed a similar petition on March 3, 2005 (Special Proceedings No. 232).
The two petitions were consolidated.

Petitioner alleged litis pendentia and prayed for the dismissal of Spec. Proc. No. 232 since Spec. Proc. No. 228 was already pending.
Respondent contended that petitioner was not an interested person qualified to file the petition due to an allegedly invalid marriage.
Respondent referred to a prior criminal bigamy case against petitioner filed by Felicitas Amor (Crim. Case No. 2699-A),

Petitioner was acquitted by the RTC of Alaminos on August 6, 1998.
The petitioner's claimed first marriage to Eusebio Bristol was disputed in the criminal case.

Branch 70 of the RTC of Burgos dismissed petitioner’s petition for letters of administration and granted respondent’s petition on June 26, 2006.
The RTC held:

Petitioner’s marriage to Bristol was valid and subsisting when she married Orlando.
Her acquittal in the bigamy case was fatal to her petition.
Petitioner was therefore not an interested party entitled to be appointed administratrix.

Petitioner filed a Petition for Certiorari with the CA alleging grave abuse of discretion by the RTC.
CA ruled on October 18, 2007:

Petitioner should have filed a petition for review, but allowed the certiorari petition filed within the period.
Litis pendentia did not apply since parties were different and special proceedings have only one party – the petitioner.
Letters of administration should be awarded to an "interested party" qualified under the Revised Rules of Court.
Petitioner was not an interested party since her marriage to Orlando was allegedly invalid due to bigamy.
The acquittal in the bigamy case did not negate the trial court’s findings.
Thus, petitioner’s dismissal was proper.

The Supreme Court noted the RTC in the special proceedings failed to consider the RTC’s findings in the bigamy case that petitioner was never married to Bristol.
The Supreme Court recognized the doctrine of comity regarding valid foreign divorce decrees obtained by naturalized foreign citizens.
Referenced landmark cases:

Van Dorn v. Romillo, Jr. (1985): Recognition of foreign divorces valid under foreign law, even if Philippine nationals cannot obtain absolute divorce.
Llorente v. Court of Appeals (2000), Quita v. Court of Appeals, and Pilapil v. Ibay-Somera: Affirming recognition of valid foreign divorce of ex-Philippine nationals.

Emphasized the need to prove the validity of the foreign divorce decree according to Rule 132 evidentiary rules.
Highlighted Garcia v. Recio case on proof and admission of foreign divorce decrees.

The trial court failed to require petitioner to prove Orlando’s divorce’s validity under U.S. law.
The Supreme Court remanded the case to the RTC for further reception of evidence to determine the validity of the divorce and subsequent marriage.
Depending on proof, letters of administration may be awarded to petitioner or respondent according to the order of preference in Rule 78, Section 6.

Whether the petitioner is an "interested party" qualified to be appointed administratrix of the intestate estate of Orlando B. Catalan.
Whether the petition for letters of administration filed by petitioner should be dismissed on the ground of litis pendentia.
Whether the petitioner’s marriage to Orlando B. Catalan is valid given the prior marriage to Eusebio Bristol and the bigamy case.
Whether the foreign divorce obtained by Orlando B. Catalan in the United States is to be recognized as valid under Philippine law.