Case Summary (G.R. No. 124862)
Underlying Marriage and Foreign Divorces
In San Francisco, Fe obtained a private agreement (19 July 1950) for property settlement and secured a U.S. divorce decree on 23 July 1954. She remarried twice thereafter in the U.S. Arturo died intestate on 16 April 1972. Blandina alleged a marriage to Arturo on 22 April 1947, void for bigamy, and claimed children with him.
Initiation of Estate Administration Proceedings
On 31 August 1972, Lino J. Inciong petitioned the RTC of Quezon City to appoint the Philippine Trust Company as administrator. Oppositions by Blandina and the Padlan children resulted in the appointment of their counsel, later replaced by Higino Castillon. Certified copies of Quita’s U.S. divorce documents were submitted on 30 April 1973.
Trial Court’s Declaration of Heirs
Petitioner moved for heirship declaration on 7 October 1987. At the 23 October 1987 hearing, other claimants defaulted. The court, invoking Tenchavez v. Escaño, disregarded the U.S. divorce and treated Quita as Arturo’s widow. It rejected Blandina’s marriage and recognized only the Padlan children and Ruperto. On 27 November 1987, the estate was equally divided between Quita and Ruperto. Partial reconsideration (15 February 1988) awarded half the estate to Quita and half among five Padlan children (excluding Alexis, deemed illegitimate).
Court of Appeals’ Remand for Hearing
Blandina and her children appealed, citing failure to hear contested heirship under Rule 90, Sec. 1. The CA on 11 September 1995 voided the RTC decisions and remanded for full hearing. Reconsideration was denied on 18 April 1996.
Governing Law and Constitutional Basis
Because the Supreme Court rendered its decision in December 1998, it applied the 1987 Philippine Constitution and pertinent Civil Code provisions on intestate succession (Arts. 998, 1001) and marriage (Arts. 80, 83).
Citizenship and Validity of Foreign Divorce as Heirship Issue
A material issue remains whether Quita retained Filipino citizenship when her U.S. divorce was decreed, invoking Van Dorn v. Romillo Jr. Aliens may obtain valid foreign divorces under their national law. The RTC never held a hearing to establish Quita’s citizenship at the time of divorce, a prerequisite to determining the divorce’s domestic effect and her status as surviving spouse.
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...continue readingCase Syllabus (G.R. No. 124862)
Facts of the Case
- Fe D. Quita and Arturo T. Padlan, both Filipino citizens, were validly married in the Philippines on 18 May 1941; their union produced no children.
- Their marriage deteriorated, leading Quita to file for divorce in San Francisco, California. She submitted a private agreement dated 19 July 1950 for legal separation and property settlement.
- On 23 July 1954, Quita obtained a final divorce decree in California. She remarried twice thereafter—first to Felix Tupaz (later divorced) and then to Wernimont—while still in the United States.
- Arturo died intestate on 16 April 1972 in the Philippines.
Procedural History
- 31 August 1972: Lino Javier Inciong petitioned the RTC of Quezon City for letters of administration over Arturo’s estate in favor of Philippine Trust Company.
- Respondents Blandina Dandan (claiming spousal status) and six Padlan children (claiming legitimacy or illegitimacy) opposed and sought appointment of their own administrator; Ruperto T. Padlan later intervened as Arturo’s brother.
- 30 April 1973: Oppositors submitted certified copies of Quita’s 1950 separation agreement and the 1954 divorce decree.
- 7 October 1987: Quita moved for immediate declaration of heirs and distribution of estate.
- 23 October 1987: On scheduled hearing, Blandina, the Padlan children, and Ruperto failed to appear. The trial court required their birth records within ten days; none were submitted.
Trial Court Ruling
- Declined to recognize Quita’s U.S. divorce under Tenchavez v. Escaño, holding that foreign divorces between Filipino citizens after the Civil Code’s effectivity are not valid in the Philippines.
- Determined Quita remained Arturo’s lawful wife at his death; disallowed her extrajudicial settlement for lack of judicial approval.
- Found no valid marriage between Arturo and Blandina; Padlan children unacknowledged as heirs.
- 27 November 1987: Declared Quita and Ruperto as intestate heirs, each entitled to one-half of the estate (Article 1001, Civil Code).
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