Case Summary (G.R. No. L-18081)
Validity of the Mohammedan Marriage
Evidence established that in 1896, Cheong Boo and Mora Adong underwent a full Quranic marriage ceremony before Iman Habubakar, including dowry payment and consummation. From that date until Cheong Boo’s death, they cohabited as husband and wife; Cheong Boo repeatedly acknowledged the marriage in official documents. The Court’s analysis:
- Section V: “Priest or minister of the Gospel of any denomination” encompasses non-Christian clergy; an Iman qualifies.
- Section VI: No formal ceremony is mandated beyond mutual declaration of consent.
- Section IX (curative clause): Validates any prior marriage solemnized by a person professing authority if either party believed in its validity, irrespective of informality.
- Government policy (Treaty of Paris, U.S. Instructions, Organic Acts, and Philippine Commission statutes) guarantees free exercise of religion and respect for local customs.
- Analogous precedents recognize Indian, Quaker, and Mormon customary marriages as valid.
- Public policy strongly favors legitimizing marriages and protecting the rights of over 150,000 Moros wed under Islamic rites.
Conclusion: The Mohammedan marriage is valid and the children born thereof are legitimate heirs.
Disposition
The Supreme Court:
- Affirms that the Chinese marriage is unproven; Cheong Seng Gee inherits as a natural child.
- Holds that the Mohammedan marriage is
Case Syllabus (G.R. No. L-18081)
Background and Facts
- Cheong Boo, a Chinese national, died intestate in Zamboanga on August 5, 1919, leaving an estate valued near ₱100,000.
- Two competing claims to his estate arose:
- Cheong Seng Gee claimed to be a legitimate son from a 1895 Chinese marriage to Tan Dit in Amoy.
- Mora Adong asserted she was lawfully married to Cheong Boo in 1896 in Basilan, bearing him five children, two surviving (Payang and Rosalia).
- Evidence included Chinese-language matrimonial correspondence, immigration documents, and testimony regarding both alleged marriages.
Procedural History
- The Court of First Instance of Zamboanga heard both claims.
- Trial judge Quirico Abeto held:
- The Chinese marriage was not sufficiently proved; Cheong Seng Gee was admitted as a natural (illegitimate) child.
- The Mohammedan marriage was proved in fact but deemed invalid under Philippine law; Payang and Rosalia likewise inherited as natural children.
- The court ordered a three-way partition of Cheong Boo’s estate among Cheong Seng Gee, Payang, and Rosalia.
- Both parties appealed to the Supreme Court.
Issues Presented
- Whether a marriage contracted in China, evidenced mainly by a matrimonial letter and witness testimony, is valid in the Philippines.
- Whether a marriage solemnized in the Philippines according to Mohammedan rites is valid under Philippine marriage law.
Supreme Court’s Factual Findings
- Agreement with the trial court that the evidence favoring the Chinese marriage was not credible or conclusive.
- Acceptance of trial court’s finding that the Mohammedan marriage in Basilan was established by direct testimony of the bride, the Iman, the bride’s father, and other eyewitnesses.
- Acknowledgment that Cheong Boo and Mora Adong cohabited continuously for 23 years, publicly presenting themselves as