G.R. No. 124862 - Quita vs. Court of Appeals

Fe D. Quita and Arturo T. Padlan, both Filipino citizens, married in the Philippines on 18 May 1941; had no children and later their relationship deteriorated.
On 19 July 1950, they executed a private writing agreeing to live separately and to settle their conjugal properties.
On 23 July 1954, Fe obtained a final judgment of divorce in San Francisco, California, U.S.A.

Three weeks after her divorce from Arturo, Fe married Felix Tupaz in California; that marriage ended in divorce.
She then married a third time to a Mr. Wernimont in the U.S.A.

Arturo died intestate on 16 April 1972, leaving no will.
On 31 August 1972, Lino Javier Inciong petitioned the RTC of Quezon City for letters of administration in favor of Philippine Trust Company.
Respondent Blandina Dandan (alias Blandina Padlan), claiming to be Arturo’s surviving spouse, and six Padlan children opposed and sought appointment of their preferred counsel; Atty. Cabasal, later replaced by Higino Castillon, was appointed administrator.
Oppositors submitted certified copies of the 1950 agreement and the 1954 divorce decree; Ruperto T. Padlan intervened as Arturo’s brother.

On 7 October 1987, Fe moved for immediate declaration of heirs and distribution of estate.
At the 23 October 1987 hearing, respondents (Blandina, the Padlan children, and Ruperto) failed to appear; the RTC required submission of children’s birth records within 10 days, after which issues would be deemed submitted.
The period lapsed without submissions. Invoking Tenchavez v. Escaño, the RTC (a) disregarded the U.S. divorce, (b) held Fe and Arturo married until his death, (c) invalidated their extrajudicial settlement for lack of judicial approval, (d) found Blandina’s marriage void and Padlan children unacknowledged (except Alexis as illegitimate), and (e) declared only Fe and Ruperto as heirs, each entitled to one-half.

On motion of Blandina and the Padlan children, birth records proved Arturo’s acknowledgment of five children (excluding Alexis).
On 15 February 1988, the RTC granted partial reconsideration: one-half of net estate to the five legitimate Padlan children, the other half to Fe; Ruperto excluded; Blandina not an heir.

Blandina and the Padlan children argued the case was decided without a hearing, violating Rule 90, Sec. 1 of the Rules of Court.
On 11 September 1995, the CA declared the RTC decisions null and void and remanded for further proceedings; denial of reconsideration on 18 April 1996.

Fe argued no remand was necessary, as heirship and shares were undisputed, and the remaining issue of spouse-heirship was one of law.
Respondents countered that Fe’s citizenship at the time of divorce was unresolved, affecting recognition of the U.S. decree under Van Dorn v. Romillo Jr.
The CA’s order to remand was challenged and forms the core dispute before the Supreme Court.

Whether a justiciable controversy exists as to who is the lawful surviving spouse and heir of Arturo Padlan.
Whether the validity of the U.S. divorce decree depends on Fe’s citizenship at the time of divorce, warranting a hearing.