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AMELIA GARCIA-QUIAZON v. MA. LOURDES BELEN

FACTS:

The case involves a Petition for Letters of Administration of the Estate of Eliseo Quiazon. Eliseo's common-law wife, Amelia Garcia-Quaizon, and their children, opposed the petition filed by Elise, claiming to be Eliseo's natural child, on the grounds of improper venue and lack of basis for Elise's appointment as administratrix. Eliseo died intestate in 1992, and Elise attached her birth certificate as evidence of her filiation. She also alleged that Eliseo's marriage to Amelia was bigamous. The Regional Trial Court (RTC) ruled in favor of Elise and directed the issuance of Letters of Administration to her. The Court of Appeals affirmed the RTC's decision, stating that Elise was able to prove her filiation and that the venue of the petition was properly laid in Las Piñas City. The petitioners, represented by Amelia, now seek a reversal of the Court of Appeals' decision on the grounds that Eliseo was not a resident of Las Piñas City, that Amelia was legally married to Eliseo, and that Elise has no interest in the petition for letters of administration.

ISSUES:

  1. Whether the venue for the settlement of the estate of the decedent was properly laid in Las Piñas City.

  2. Whether the Court of Appeals erred in declaring the marriage of the decedent as void ab initio.

  3. Whether Elise, as a compulsory heir, has the right to impugn her father's marriage to Amelia even after the death of her father.

  4. Whether the marriage between Eliseo and Amelia is void for being bigamous.

  5. Whether Elise has shown any interest in the Petition for Letters of Administration.

RULING:

  1. Yes, the venue for the settlement of the estate of the decedent was properly laid in Las Piñas City. The term "resides" in the context of venue provisions means the personal, actual, or physical habitation of a person, signifying physical presence and actual stay. Since the decedent resided in Las Piñas City during his lifetime, the venue for the settlement of his estate may be laid in the said city.

  2. No, the Court of Appeals did not err in declaring the marriage of the decedent as void ab initio. In a void marriage, it is as though no marriage has taken place, rendering it incapable of being the source of rights. Any interested party may attack the marriage directly or collaterally. The fact that the decedent filed an action for judicial partition of properties against his supposed wife on the ground of their marriage being void supports the conclusion that the marriage was void ab initio.

  3. Elise, as a compulsory heir, has the right to impugn her father's marriage to Amelia even after the death of her father. She has a cause of action for the declaration of the absolute nullity of the void marriage and the death of either party to the said marriage does not extinguish such cause of action.

  4. The marriage between Eliseo and Amelia is void for being bigamous. The existence of a previous marriage between Amelia and Filipito was sufficiently established and the absence of any showing that such marriage had been dissolved at the time Amelia and Eliseo's marriage was solemnized leads to the conclusion that the latter marriage is bigamous and, therefore, void ab initio.

  5. Elise, as a compulsory heir who stands to be benefited by the distribution of Eliseo's estate, is deemed to be an interested party. Her lack of interest in the administration of the decedent's estate does not diminish her right to be appointed administratix of the estate. She is entitled to her legitime as one of the decedent's natural children and can rightfully be considered as an interested party within the purview of the law.

PRINCIPLES:

  • The term "resides" in the context of venue provisions signifies the personal, actual, or physical habitation of a person, requiring physical presence and actual stay.

  • Recitals in death certificates regarding the decedent's residence at the time of death can be considered as evidence but are not binding on courts.

  • Factual findings of the trial court, when affirmed by the appellate court, are conclusive and binding.

  • In a void marriage, no marriage has taken place and it cannot be the source of rights, making it open to attack by any interested party.

  • The marriage cannot be the source of rights, and any interested party may attack the marriage directly or collaterally without prescription, even beyond the lifetime of the parties to the marriage.

  • A party may impugn the existence of a marriage that would prejudice their successional rights even after the death of one of the parties.

  • The existence of a previous marriage can be proven through a marriage certificate, and the absence of a record of marriage does not negate the existence of the previous marriage.

  • An interested party in estate proceedings refers to one who would be benefited in the estate, such as an heir, or one who has a claim against the estate, such as a creditor.

  • A compulsory heir has the right to be appointed as an administrator of the estate and is considered an interested party in estate proceedings.