Case Summary (G.R. No. 185374)
Petitioners’ Position
Petitioners assert that Vicente Sr. first validly married Benita in 1929, evidenced by a Contrato Matrimonial and supporting ecclesiastical and civil certifications. They contend that any later marriage between Vicente Sr. and Leonora was bigamous and void, rendering the extrajudicial settlement defective for depriving petitioners of their inheritance shares.
Respondents’ Position
Respondents maintain that they legitimately inherited from Vicente Sr. by virtue of his valid marriage to Leonora in 1977, as shown by a civil marriage certificate. They challenge petitioners’ proof of the 1929 marriage and their own standing, invoke estoppel by laches, and characterize petitioners’ documents as inadmissible private writings and hearsay.
Key Dates
• Marriage of Vicente Sr. and Benita: October 9, 1929
• Alleged marriage of Vicente Sr. and Leonora: June 27, 1977
• Extrajudicial settlement executed: September 1998
• RTC decision nullifying the settlement: January 30, 2007
• CA decision reversing RTC: August 5, 2008
• Supreme Court resolution denying reconsideration: November 14, 2008
• Supreme Court decision affirming CA: March 11, 2015
Applicable Law
Under the 1987 Constitution and the Rules of Court (Rule 132, Sections 20–21), public documents are self-authenticating while private writings require proof of execution. An “ancient document” over thirty years old may be exempted from authentication if produced from proper custody. Certificates of baptism prove only the performance of the sacrament, not the truth of familial statements. Hearsay affidavits are inadmissible absent live testimony.
Facts and Procedural History
Petitioners challenged the extrajudicial settlement on grounds that they, as legitimate heirs of Vicente Sr. and Benita, were entitled to their shares in the subject land. They presented a church-issued Contrato Matrimonial, church certification of its acceptance, civil-registry denials of birth records, baptismal certificates, and a joint affidavit attesting to Ligaya’s parentage. The RTC found petitioners’ evidence sufficient, declared the settlement void, and apportioned the property. The CA reversed, holding petitioners failed to prove the 1929 marriage or filiation.
Trial Court’s Findings
The RTC accepted the Contrato Matrimonial as proof of marriage, deemed the Leonora marriage bigamous, and ruled that respondents’ settlement violated petitioners’ legitimes and Benita’s surviving-spouse rights. It ordered property shares, damages, and attorney’s fees in favor of petitioners.
Court of Appeals’ Ruling
The CA held the Contrato Matrimonial a private document lacking authentication, disregarded the baptismal certificate as insufficient to establish filiation, and struck the joint affidavit as hearsay. It concluded petitioners had not met their evidentiary burden and reinstated the extrajudicial settlement’s validity.
Issues on Review
- Whether the Contrato Matrimonial is a public or private document and whether it was properly authenticated.
- Whether the Contrato Matrimonial qualifies as an ancient document exempt from authentication.
- Whether baptismal certificates and a joint affidavit sufficiently prove petitioners’ filiation.
- Whether the subsequent marriage was bigamous and subject to collateral attack.
Marriage Contract as Private Document
The Supreme Court reaffirmed that church records are private writings post-American occupation and require authentication under Rule 132, Section 20. Petitioners offered no witness to testify to execution or recognize signatures. Possession of a “duplicate original” lacked certification or public-officer acknowledgment, rendering it inadmissible.
Authentication and Ancient Document Exception
Although over thirty years old, the Contrato Matrimonial was not shown to come from proper custody. Petitioners did not demonstrate why the document was found in Simplicia’s hands rather than with a rightful custodian. Without satisfying all three requireme
...continue readingCase Syllabus (G.R. No. 185374)
Facts of the Case
- Petitioners Simplicia Cercado-Siga and Ligaya Cercado-Belison claim to be legitimate children of the late Vicente Cercado, Sr. and his first wife, Benita Castillo, married on 9 October 1929 in Pililla, Rizal.
- Vicente Sr. acquired by gratuitous title a 6,032-square-meter parcel of land (Lot No. 7627 Cad 609-D, Barangay Kinagatan, Binangonan, Rizal).
- Upon Vicente Sr.’s death, petitioners assert that by intestate succession they inherited the entire property; upon Benita’s death, petitioners inherited her share by operation of law.
- In September 1998, petitioners discovered an Extrajudicial Settlement of Estate between respondents (heirs of Vicente Sr. and Leonora Ditablan) purportedly disposing of the same land.
- Petitioners maintain that Vicente Sr.’s purported marriage to Leonora was null and void, and they moved to annul the Deed, correct the civil registry, and recover damages and attorney’s fees.
Petitioners’ Evidence
- Contrato Matrimonial (marriage contract) dated 9 October 1929.
- Certification (19 November 2000) from Iglesia Filipina Independiente accepting the original marriage contract.
- Certification of non-production of Simplicia’s birth record from the Municipal Civil Registrar of Pililla, Rizal.
- Certificate of Baptism of Simplicia.
- Certification of non-production of Ligaya’s birth record from the same local registrar.
- Joint affidavit of two disinterested persons attesting that Ligaya is the daughter of Vicente Sr. and Benita.
Respondents’ Allegations
- Respondents assert they are the legitimate heirs of Vicente Sr. and Leonora, married on 27 June 1977 (registered with the Local Civil Registrar of Binangonan, Rizal).
- Petitioners lack standing for failure to present birth certificates proving filiation.
- The 1929 Contrato Matrimonial is not a certified true copy and thus without probative value.
- Petitioners are estopped by laches from challenging the Extrajudicial Settlement.
RTC Proceedings and Decision
- The Regional Trial Court of Bi