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EDGAR SAN LUIS v. FELICIDAD SAN LUIS

FACTS:

The case involves the settlement of the estate of Felicisimo T. San Luis, a former governor of the Province of Laguna, who had three marriages during his lifetime. His first marriage was with Virginia Sulit, with whom he had six children. Virginia predeceased Felicisimo. Five years later, Felicisimo married Merry Lee Corwin and had a son, Tobias. However, Merry Lee filed for divorce in the United States, which was granted. On June 20, 1974, Felicisimo married respondent Felicidad San Luis. They had no children together but lived as husband and wife for 18 years until Felicisimo's death.

Respondent sought the dissolution of their conjugal partnership assets and the settlement of Felicisimo's estate. She filed a petition for letters of administration before the regional trial court. Petitioner Rodolfo San Luis, one of Felicisimo's children from his first marriage, filed a motion to dismiss the petition, arguing improper venue and respondent's lack of legal personality. Linda, another child of Felicisimo, also filed a motion to dismiss on the same grounds. The trial court denied the motions to dismiss.

Respondent filed an opposition, presenting evidence to prove Felicisimo's residence in Metro Manila and the dissolution of his second marriage. Linda, Rodolfo, and petitioner Edgar San Luis separately filed motions for reconsideration. Mila, another daughter of Felicisimo, filed a motion to disqualify the acting presiding judge. The trial court denied the motions for reconsideration and ruled in favor of respondent's legal standing and proper venue.

Mila filed a motion for inhibition against the judge, and the case was re-raffled to another judge. The trial court required the parties to submit their respective position papers, after which the trial court dismissed the petition.

Felicisimo and respondent entered into a marriage while the former's marriage to Merry Lee was still subsisting. Felicisimo died intestate in Makati City. Respondent filed a petition for letters of administration in Makati City, while Felicisimo's legitimate children (petitioners) argued that the petition should have been filed in Sta. Cruz, Laguna, where Felicisimo resided as the duly elected governor of Laguna. The trial court dismissed the petition, finding that Felicisimo was a resident of Laguna and that respondent's marriage to him was bigamous and void ab initio. Respondent appealed to the Court of Appeals, which reversed the trial court's decision and held that the petition was properly filed in Makati City. The Court of Appeals also ruled that Felicisimo had legal capacity to marry respondent and that paragraph 2, Article 26 of the Family Code applied to their case. Petitioners appealed to the Supreme Court, questioning the venue and respondent's legal capacity to file the petition.

The case involves a dispute over the proper venue for the settlement of the estate of the deceased Felicisimo. The petitioners argue that "residence" is synonymous with "domicile" for purposes of determining venue, while the respondent argues that "residence" refers to personal, actual, or physical habitation, which may not necessarily be the same as one's legal residence or domicile. The petitioners claim that the deceased was domiciled in Sta. Cruz, Laguna, while the respondent presents evidence that he also maintained a residence in Alabang, Muntinlupa from 1982 until his death. The respondent submitted a Deed of Absolute Sale and billing statements indicating the address of the deceased at "100 San Juanico, Ayala."

ISSUES:

  1. Whether venue was properly laid

    • The petitioners argue that the venue for the petition of letters of administration should have been in Sta. Cruz, Laguna, not Makati City, as Sta. Cruz, Laguna was Felicisimo's legal residence.

  2. Whether the respondent has legal capacity to file the petition for letters of administration

    • Petitioners claim that respondent Felicidad San Luis has no legal capacity to file the petition because her marriage to Felicisimo is void and bigamous.

RULING:

  1. Venue

    • The Supreme Court ruled that venue was properly laid in Makati City because for the purposes of fixing the venue, "residence" connotes "actual residence" rather than "legal residence" or "domicile." Felicisimo was found to have actually resided in Alabang, Muntinlupa, despite being domiciled in Sta. Cruz, Laguna.

  2. Legal Capacity to File Petition for Letters of Administration

    • The Supreme Court ruled that Felicidad has the legal capacity to file the petition either as the surviving spouse of Felicisimo or as his co-owner under Article 144 of the Civil Code or Article 148 of the Family Code. This determination was made on the conditional basis of further evidence on the validity of the divorce decree obtained by Merry Lee and the subsequent marriage between Felicisimo and Felicidad.

PRINCIPLES:

  1. Residence for Venue Purposes

    • "Residence" for the purpose of venue is distinct from "domicile." It signifies actual residence or physical habitation rather than legal residence.

  2. Article 26, Family Code (second paragraph)

    • Recognizes the capacity of a Filipino citizen to remarry if divorced by an alien spouse abroad, as per the ruling in Van Dorn v. Romillo, Jr.

  3. Co-Ownership under Article 144 of the Civil Code

    • Governs property relations between parties who live together as husband and wife without the benefit of marriage or when their marriage is void, establishing a presumption of joint ownership of property acquired during their cohabitation.

  4. Article 148 of the Family Code

    • Applicable to couples living together as husband and wife but who are legally incapacitated to marry, establishing a regime of limited co-ownership based on their actual contributions.

  5. Burden of Proof for Foreign Law

    • Foreign laws and judgments, such as divorce decrees, require strict proof of authenticity and due execution in accordance with Philippine Evidence law (Sections 24 and 25, Rule 132).