Title
Alfelor vs. Halasan
Case
G.R. No. 165987
Decision Date
Mar 31, 2006
Dispute over intestate estate; Josefina, claiming to be Jose Alfelor's surviving spouse, intervened, citing Teresita's judicial admission of prior marriage. SC affirmed intervention.

Case Summary (G.R. No. 165987)

Key Dates and Procedural Milestones

Complaint for partition filed: January 30, 1998.
Intervention filed by Josefina Halasan: October 20, 1998 (with Answer in Intervention and machine copy of a marriage contract).
RTC Order dismissing intervention: September 13, 2002 (denying intervention and declaring Teresita and her children legitimate heirs).
RTC denial of motion for reconsideration: October 30, 2002.
CA Decision reversing the RTC: November 5, 2003 (ordered RTC to admit intervention and conduct proceedings).
Supreme Court decision: March 31, 2006 (affirming the CA).

Factual Background Relevant to Disputed Questions

Jose K. Alfelor allegedly married Josefina Halasan on February 1, 1956 (documentary machine copy produced by Josefina). He later contracted a civil marriage with Teresita on February 12, 1966 and a religious marriage on April 30, 1966. Teresita and her children claimed legitimacy and inheritance rights; Josefina asserted she was the first and surviving spouse and thus had an interest in Jose’s intestate share in his parents’ estate. Josefina did not personally testify at the RTC hearing; Teresita did, and both a written Reply-in-Intervention and oral testimony by Teresita contained statements acknowledging knowledge of a prior marriage of Jose to Josefina.

RTC Findings and Rationale

The RTC dismissed Josefina’s complaint-in-intervention for failure to prove the first marriage. The trial court emphasized the lack of primary testimony from Josefina, the absence of witnesses identifying or authenticating the marriage document as an original, and a deficiency in compliance with evidentiary formalities. The RTC found that Teresita contracted the subsequent marriage in good faith (not knowing of an existing valid marriage) and relied on that good faith to declare Teresita and her children legitimate heirs. The RTC applied Sarmiento v. Court of Appeals regarding requirements to prove validity of a marriage when contested.

Grounds of the CA Reversal

The Court of Appeals reversed the RTC, holding that Teresita’s express admissions—both in her written Reply-in-Intervention and in oral testimony—that she knew of Jose’s prior marriage to Josefina constituted judicial admissions. Applying Section 4, Rule 129 of the Revised Rules of Evidence (that admissions need not be proved), the CA concluded that proof of Josefina’s marriage to Jose was dispensed with. The CA relied on precedent that a judicial admission is conclusive and cannot be later controverted by the admitting party; therefore, the RTC gravely abused its discretion when it dismissed the intervention for “insufficient proof.”

Legal Issue Presented to the Supreme Court

Whether the CA erred in ordering the admission of Josefina Halasan’s intervention in the partition action — principally whether Teresita’s statements constituted a judicial admission that dispensed with further proof of the prior marriage and whether, on that basis, Josefina had the requisite legal interest to intervene under Rule 19, Section 1 of the Revised Rules of Court.

Supreme Court’s Analysis — Judicial Admission Doctrine

The Court characterized Teresita’s statements as deliberate, clear, and unequivocal statements made in the course of judicial proceedings and therefore qualifying as judicial admissions. The Court reiterated the legal effect of a judicial admission: it is a waiver of proof, removes the admitted fact from controversy, is binding on the party making it, and cannot later be contradicted by that party. The Court concluded that because the existence of the first marriage had been judicially admitted by petitioners’ mother, the formal proof the RTC demanded was unnecessary under Section 4, Rule 129.

Supreme Court’s Analysis — Intervention Under Rule 19

The Court examined Section 1, Rule 19 (who may intervene) and found that Josefina had a direct, immediate legal interest in the matter in litigation — specifically, in the share of the decedent husband’s intestate estate that was the object of the partition action. The Court relied on controlling principles that intervention is appropriate where the intervenor stands to gain or lose legally by the judgment and where their rights might be adversely affected by disposition of property in the custody of the court. Prior jurisprudence cited by the Court (e.g., Nordic Asia; Uy v. Court of Appeals) supported the proposition that, under such circumstances, intervention ought to be permitted so as to adjudicate the whole controversy and protect indispensable or directly affected rights.

Consideration of Evidentiary Objections and Hearsay Arguments

Petitioners argued that Teresita’s written admission in the Reply-in-Intervention was hearsay and lacked probative value because she claimed that her knowledge of the prior marriage was derived from others. The Supreme Court rejected this approach to the point that, once characterized as a judicial admission (a clear, unequivocal statement made in pleadings and testimony), the admission was conclusively binding and did not require extrinsic proof; consequently the hearsay contention could not negate the admission’s binding effect.

Distinction from Sarmiento and Other Authorities

The Court clarified that Sarmiento v. Court of Appeals (which dealt with proof and validity of a marriage) did not control the intervention question here because the present appeal turned on the ad

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