Case Digest (G.R. No. 189121) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Amelia Garcia-Quiazon, et al. v. Ma. Lourdes Belen, for and in behalf of Maria Lourdes Elise Quiazon (G.R. No. 189121, July 31, 2013), Eliseo Quiazon died intestate on December 12, 1992. On September 12, 1994, his natural daughter Maria Lourdes Elise Quiazon, through her mother Ma. Lourdes Belen, filed a Petition for Letters of Administration (SP Proc. No. M-3957) before the RTC of Las Piñas City, alleging that she was conceived and born while her parents were capacitated to marry and impugning as bigamous and void the subsequent marriage of Eliseo to petitioner Amelia Garcia-Quiazon. She attached her birth certificate signed by Eliseo as proof of filiation and detailed the decedent’s assets. Petitioners Amelia, Jenneth, and Maria Jennifer Quiazon opposed on grounds of improper venue—citing Eliseo’s alleged residence in Capas, Tarlac—and questioned Elise’s competence and interest. On March 11, 2005, the RTC granted the petition, holding that Eliseo’s actual residence was in L Case Digest (G.R. No. 189121) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Petitioners: Amelia Garcia-Quiazon (legal wife of the decedent) and her children, Jenneth and Maria Jennifer Quiazon.
- Respondent: Ma. Lourdes Belen, on behalf of her daughter Maria Lourdes Elise Quiazon, petitioning for Letters of Administration.
- Decedent and Estate
- Eliseo Quiazon died intestate on December 12, 1992.
- Alleged estate consisted of real properties worth ₱2,040,000.00 and personal properties worth ₱2,100,000.00.
- Petition for Letters of Administration
- Filed on September 12, 1994 in the RTC of Las Piñas City, SP Proc. No. M-3957, by Elise (through her mother) claiming to be the natural child of Eliseo.
- Elise attached her Certificate of Live Birth signed by Eliseo and asserted that her father’s marriage to Amelia was void due to a pre-existing marriage with one Filipito Sandico.
- Opposition and Venue Dispute
- Petitioners challenged venue, relying on Eliseo’s Death Certificate indicating residency in Capas, Tarlac.
- They also contended Elise lacked factual and legal basis to serve as administratrix.
- Proceedings Below
- RTC Decision (March 11, 2005) granted Letters of Administration to Elise upon posting a ₱100,000 bond, finding las Piñas City as decedent’s residence.
- Court of Appeals Decision (November 28, 2008) affirmed the RTC, upholding venue and Elise’s filiation. Motion for Reconsideration denied (August 7, 2009).
Issues:
- Venue
- Whether the Court of Appeals gravely erred in affirming that Eliseo was a resident of Las Piñas City, thus proper venue.
- Validity of Marriage
- Whether the Court of Appeals erred in declaring the marriage between Amelia and Eliseo void ab initio for bigamy.
- Interest in Estate
- Whether Elise lacks the requisite interest to file the Petition for Letters of Administration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)