Case Summary (G.R. No. 189121)
Procedural History
- September 12, 1994: Elise (through Lourdes) filed Petition for Letters of Administration (SP Proc. No. M-3957) before RTC, Branch 275, Las Piñas City.
- Petition opposed by Amelia et al. on grounds of improper venue and lack of entitlement.
- March 11, 2005: RTC granted letters of administration to Elise upon bond.
- March 24, 2006: RTC order affirmed its decision.
- November 28, 2008: Court of Appeals (CA) denied petitioners’ appeal, affirming RTC in toto.
- August 7, 2009: CA denied motion for reconsideration.
- Petition for Review on Certiorari under Rule 45 filed before the Supreme Court.
Applicable Law
1987 Constitution (venue and due process principles).
Revised Rules of Court: Rule 73, Section 1 (venue for settlement of estate); Rule 78, Section 6 and Rule 79, Section 2 (administration proceedings).
Civil Code (bigamy provisions; succession rights of legitimate and illegitimate children).
Facts and Contest of Venue
Elise claimed actual residence of Eliseo was at No. 26 Everlasting Road, Pilar Village, Las Piñas City, having lived there with Lourdes from 1975 until Eliseo’s death. Certificate of Death listed residence as Capas, Tarlac. Petitioners argued venue lay in Tarlac per Section 1, Rule 73. RTC and CA held death certificate recitals were not conclusive, crediting multiple proofs of actual abode in Las Piñas City.
Issue of Marriage Validity
Elise impugned the marriage of Eliseo and Amelia as void ab initio due to pre-existing marriage of Amelia to Filipito Sandico. Certificate of Marriage from Diocese of Tarlac established first marriage. No proof of its dissolution. Under Old Civil Code Article 83, second marriage was void for bigamy unless the first was annulled.
Filiations and Right to Administration
Elise attached her certified birth certificate signed by Eliseo. As natural (illegitimate) child, she is a compulsory heir under Civil Code Articles 961 and 988. Petitioners claimed Elise lacked interest. Supreme Court held that any heir entitled to share in the estate is an “interested person” within Rule 79 and eligible for appointment under
Case Syllabus (G.R. No. 189121)
Facts
- Eliseo Quiazon died intestate on December 12, 1992, leaving real properties worth ₱2,040,000.00 and personal properties worth ₱2,100,000.00.
- On September 12, 1994, Ma. Lourdes Elise Quiazon (represented by Ma. Lourdes Belen) filed SP Proc. No. M-3957 in the RTC of Las Piñas City, seeking letters of administration for her daughter Maria Lourdes Elise Quiazon (Elise).
- Elise alleged she was the natural child of Eliseo, conceived and born when her parents were capacitated to marry, and challenged the validity of Eliseo’s marriage to Amelia Garcia-Quiazon as bigamous.
- Elise attached her Certificate of Live Birth, signed by Eliseo, to establish filiation.
- Petitioners (Amelia, Jenneth and Maria Jennifer Quiazon) opposed on grounds of improper venue—citing Eliseo’s residence in Capas, Tarlac per his Death Certificate—and lack of basis for Elise’s appointment.
Procedural History
- RTC Branch 275, Las Piñas City: March 11, 2005 Decision directing issuance of letters of administration to Elise upon posting of ₱100,000 bond; Order of March 24, 2006 approving bond.
- Court of Appeals (CA-G.R. CV No. 88589): November 28, 2008 Decision affirming the RTC in toto; August 7, 2009 Resolution denying motion for reconsideration.
- Supreme Court: Petition for Review on Certiorari under R