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Anonuevo Vs Intestate Estate

The petitioners sought to enforce the right of their grandmother Isabel Blee to inherit from Rodolfo Jalandoni, claiming Isabel was his legal wife. However, the respondent argued that Isabel's marriage to Rodolfo was null and void because Sylvia Blee Desantis' birth certificate showed that Isabel was already married to John Desantis at the time. The Court of Appeals upheld the ruling nullifying Isabel's marriage to Rodolfo based on Sylvia's birth certificate being evidence that Isabel and John were married, making her subsequent marriage to Rodolfo bigamous.

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127 views2 pages

Anonuevo Vs Intestate Estate

The petitioners sought to enforce the right of their grandmother Isabel Blee to inherit from Rodolfo Jalandoni, claiming Isabel was his legal wife. However, the respondent argued that Isabel's marriage to Rodolfo was null and void because Sylvia Blee Desantis' birth certificate showed that Isabel was already married to John Desantis at the time. The Court of Appeals upheld the ruling nullifying Isabel's marriage to Rodolfo based on Sylvia's birth certificate being evidence that Isabel and John were married, making her subsequent marriage to Rodolfo bigamous.

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Kê Milan
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© © All Rights Reserved
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RAQUEL Q.

CANDELARIA
LS2019-00062

MAY D. AÑONUEVO, ALEXANDER BLEE DESANTIS and JOHN


DESANTIS vs. INTESTATE ESTATE OF RODOLFO G.
JALANDONI
G.R. No. 178221, December 1, 2010
Perez, J

FACTS:

The petitioners, May D. Añonuevo and siblings seek to enforce the right of
their grandmother Isabel Blee who was at the time of death of Rodolfo
Jalandoni claimed to be the legal wife based on marriage certificate. They
introduced themselves as the children of Sylvia Blee Desantis, who was
revealed to be the daughter of Isabel with John Desantis.

The respondent who is represented by Special Administrator Bernardino


Jalandoni, the brother of Rodolfo, opposed the intervention because the birth
certificate of Sylvia states that Isabel and John are married. Therefore,
Isabel’s marriage to Rodolfo is null and void. Further, regarding Sylvia’s
legitimacy and the status of her parents in order to save face is customary.

The Court of Appeals granted the petition and nullified the orders of the
intestate court allowing petitioners and siblings to take part in settlement
proceedings.

ISSUE:

Whether or not the Court of Appeals erred when it nullified the orders of the
intestate court allowing the petitioners and their siblings to intervene in the
settlement proceedings.

RULING:

No, the Court of Appeals acted within the limits of review under a writ of
certiorari. The re-assessment of evidence proving Isabel’s right to inherit
from Rodolfo is an indispensable requisite to justify an intervention. Thus,
Sylvia’s birth certificate proves that Isabel and John Desantis were married
and that Sylvia is their legitimate child. It then follows that the marriage
between Isabel and Rodolfo is null for being bigamous. The petitioner and
their siblings failed to show that Isabel has any interest in the estate of
Rodolfo.

1
“While a marriage certificate is considered the primary evidence of a marital
union, it is not regarded as the sole and exclusive evidence of marriage.
Jurisprudence teaches that the fact of marriage may be proven by relevant
evidence other than the marriage certificate. Hence, even a person’s birth
certificate may be recognized as a competent evidence of the marriage
between his parents.” The reason to “save face” is customary and without
merit which the court cannot countenance.

Lesson Learned in Relation to the Family Code

I have learned legal presumptions of marriage. That child’s birth certificate


stating parents were married, establishes the presumption that indeed they
were married.

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