G.R. No. 189121 - Garcia-Quiazon vs. Belen

Case Summary (G.R. No. 189121)

Petitioners

Amelia and her children opposed the Petition for Letters of Administration filed in the Regional Trial Court (RTC) of Las Piñas City and later appealed the denial of their motion to dismiss. They asserted improper venue (claiming Eliseo’s residence at death was Capas, Tarlac), challenged the appointment of Elise as administratrix, and maintained that Amelia’s marriage to Eliseo was valid.

Respondent

Elise, represented by her mother Lourdes, filed the Petition for Letters of Administration. Elise claimed to be the natural child of Eliseo, attached her birth certificate signed by Eliseo, sought appointment as administratrix to preserve the estate, and alleged Eliseo and Lourdes lived together as husband and wife in Las Piñas.

Key Dates and Procedural Posture

Eliseo died intestate on 12 December 1992. Petition for Letters of Administration was filed 12 September 1994 (SP Proc. No. M-3957) in the RTC of Las Piñas City. RTC issued letters of administration to Elise (Decision dated 11 March 2005). The Court of Appeals affirmed (Decision dated 28 November 2008) and denied reconsideration (Resolution dated 7 August 2009). Supreme Court decision denying the petition for review on certiorari affirmed the lower courts’ rulings.

Applicable Law (including constitutional basis)

Because the decision date is after 1990, the 1987 Philippine Constitution is the governing constitution for the resolution of the petition. The controlling procedural and substantive provisions applied were Section 1, Rule 73 (venue for settlement of estates), Section 6, Rule 78 and Section 2, Rule 79 (who may be granted letters of administration and contents of petition), provisions of the New Civil Code on succession (Arts. 961, 988), and the Old Civil Code provision on bigamy (Art. 83) applicable at the time the questioned marriage was solemnized. Relevant jurisprudence cited includes Niñal v. Bayadog and related cases on residence, venue and the distinction between void and voidable marriages.

Facts Relevant to Venue and Succession

Elise asserted that Eliseo and Lourdes established a common residence at No. 26 Everlasting Road, Phase 5, Pilar Village, Las Piñas City from 1975 until Eliseo’s death in 1992. Elise produced a birth certificate signed by Eliseo and alleged assets of the decedent. Petitioners relied on the decedent’s death certificate listing residence as Capas, Tarlac and argued venue should be in Tarlac. Evidence in the record also included a prior judicial action (Quiazon v. Garcia, Civil Case No. Q-43712) in which Eliseo had sought partition on the ground that his marriage to Amelia was void for bigamy.

Trial Court Ruling

The RTC found venue in Las Piñas proper, discredited the petitioners’ reliance on the death certificate as hearsay regarding residence, and concluded that Eliseo had actually been living with Lourdes in Las Piñas until his death. The RTC granted letters of administration to Elise upon posting of bond, finding no disqualification to serve as administratrix.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC in toto. It gave weight to proof that Eliseo and Lourdes lived together as husband and wife in Las Piñas, held that Elise’s filiation to Eliseo was sufficiently established, and accepted Las Piñas as the decedent’s residence for venue purposes.

Issues Presented to the Supreme Court

Petitioners raised three principal issues: (1) whether the Court of Appeals erred in finding Eliseo a resident of Las Piñas and thus that venue was proper in Las Piñas; (2) whether the Court of Appeals erred in declaring Amelia’s marriage to Eliseo void due to Amelia’s pre-existing marriage (bigamy); and (3) whether Elise had shown any interest in the Petition for Letters of Administration.

Supreme Court Analysis — Venue and Meaning of “Resides”

The Supreme Court applied Section 1, Rule 73, holding that venue for settlement of an estate is in the RTC of the province where the decedent “resides” at death. The Court reiterated established law that the term “resides” in venue statutes denotes actual, physical residence (actual habitation or place of abode), not domicile in the technical sense. The Court found the RTC’s factual finding—that Eliseo actually resided in Las Piñas with Lourdes—supported by record evidence (address evidence and prior litigation indicating his separation from Amelia). The death certificate notation of residence in Capas, Tarlac was not binding; recitals in a death certificate are not conclusive on courts. Appellate affirmation of factual findings rendered those findings conclusive. Consequently, venue in Las Piñas was correct.

Supreme Court Analysis — Validity of the Marriage (Void vs. Voidable; Bigamy)

Applying the Civil Code in force at the time of the marriage, the Court treated the question of bigamy under the Old Civil Code (Art. 83). The Court reiterated the well-established distinction: a void marriage may be attacked by any interested person even after the death of the parties, whereas voidable marriages may be attacked only during the lifetime of the parties. Citing Niñal v. Bayadog, the Court held that Elise, as an interested heir whose succession rights would be affected, could impugn the validity of the marriage between Eliseo and Amelia in the estate proceedings. The Co

Case Syllabus (G.R. No. 189121)

Procedural Posture

Petition for Review on Certiorari filed with the Supreme Court pursuant to Rule 45, assailing the 28 November 2008 Decision of the Court of Appeals in CA-G.R. CV No. 88589 and the Court of Appeals' 7 August 2009 Resolution denying reconsideration.
The Supreme Court opinion was penned by Justice Perez and promulgated on 31 July 2013 (G.R. No. 189121). The Second Division rendered the decision with Justices Carpio (Chairperson), Brion, Del Castillo, and Perlas-Bernabe concurring.
The petition sought reversal of the Court of Appeals’ affirmance of the Regional Trial Court (RTC), Branch 275, Las Piñas City, which had issued Letters of Administration to respondent Ma. Lourdes Elise Quiazon (Elise) represented by Ma. Lourdes Belen (Lourdes).

Relevant Lower Court Orders and Dates

RTC Decision dated 11 March 2005 (penned by Judge Bonifacio Sanz Maceda) directing issuance of Letters of Administration to Elise upon posting of bond.
Court of Appeals Decision dated 28 November 2008 in CA-G.R. CV No. 88589 affirming the RTC Decision in toto (opinion penned by Associate Justice Ramon R. Garcia with Associate Justices Josefina Guevara-Salonga and Magdangal M. De Leon concurring).
Court of Appeals Resolution dated 7 August 2009 denying petitioners’ motion for reconsideration.
Supreme Court Order: petition denied; Court of Appeals Decision and Resolution affirmed in toto.

Parties and Capacities

Petitioners: Amelia Garcia-Quiazon (Amelia), and her children Jenneth Quiazon and Maria Jennifer Quiazon — opposed the petition for Letters of Administration.
Respondent/Petitioner in Special Proceeding: Ma. Lourdes Elise Quiazon (Elise), represented by her mother Ma. Lourdes Belen — sought appointment as administratrix of the estate of Eliseo Quiazon (the decedent).
Decedent: Eliseo Quiazon (Eliseo), who died intestate. The source contains multiple references to the date of death: one statement that Eliseo died intestate on 12 December 1992 and another reference stating death in 1995.

Factual Background

Elise filed a Petition for Letters of Administration (Special Proceeding No. M-3957) on 12 September 1994 in the RTC of Las Piñas City, alleging she is the natural child of Eliseo and that her parents were capacitated to marry each other.
Elise attached a Certificate of Live Birth signed by Eliseo as her father to prove filiation.
Elise alleged Eliseo left real properties valued at P2,040,000.00 and personal properties valued at P2,100,000.00, and sought appointment as administratrix to preserve the estate and prevent dissipation.
Amelia and her children opposed the petition by filing an Opposition/Motion to Dismiss, asserting improper venue for the petition because Eliseo’s Death Certificate listed his residence as Capas, Tarlac.
The petitioners contended administration should have been filed in Capas, Tarlac pursuant to Section 1, Rule 73 of the Revised Rules of Court.
Trial court found venue in Las Piñas proper, discredited the petitioners’ claim of residence in Capas as hearsay, and allowed issuance of Letters of Administration to Elise after posting a bond of P100,000.00.

Procedural and Evidentiary Posture at Trial and on Appeal

Trial court (RTC) issued Letters of Administration to Elise upon approval of a P100,000 bond, having found she had attained legal age and showed no disqualification or incompetence to serve.
On appeal, the Court of Appeals affirmed the RTC, finding Elise proved that Eliseo and Lourdes lived together as husband and wife and established a common residence at No. 26 Everlasting Road, Phase 5, Pilar Village, Las Piñas City from 1975 until Eliseo’s death.
Petitioners’ motion for reconsideration before the Court of Appeals was denied on 7 August 2009.

Issues Presented to the Supreme Court

Whether the Court of Appeals gravely erred in concluding Eliseo was a resident of Las Piñas City and that the petition for Letters of Administration was properly filed in the RTC of Las Piñas.
Whether the Court of Appeals gravely erred in declaring that Amelia’s marriage to Eliseo was void due to a pre-existing marriage (bigamy).
Whether the Court of Appeals overlooked that Elise had not shown any interest in the Petition for Letters of Administration.

Petitioners’ Contentions (as presented in source)

Venue was improperly laid in Las Piñas because Eliseo’s Death Certificate lists his residence as Capas, Tarlac, so administration should have been filed in Capas, Tarlac.
The Court of Appeals erred in declaring Amelia was not legally married to Eliseo for pre-existing marriage.
Elise lacked sufficient interest to be appointed administratrix.

Respondent’s Position and Proofs (as recited)

Elise asserted she was the natural child of Eliseo and that her parents were capacitated to marry.
Elise presented a Certificate of Live Birth signed by Eliseo as father to prove filiation.
Elise proved cohabitation and marital comportment between Eliseo and Lourdes and established a common residence in Las Piñas from 1975 up to the decedent’s death.
Elise’s documentary proofs and factual showing supported appointment as administratrix and proper venue in Las Piñas.

Evidence and Documentary Exhibits Referred

Certificate of Live Birth of Elise (signed by Eliseo).
Eliseo’s Death Certificate (indicating residence in Capas, Tarlac).
Certificate of Marriage issued by the Diocese of Tarlac, signed by the officiating priest of the Parish of San Nicolas de Tolentino in Capas, Tarlac (establishing Amelia’s prior marriage to Filipito Sandico