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Amelia Garcia-Quiazon, et.al. v. Ma.

Lourdes Belen
G.R. No. 189121, July 31, 2013
Perez, J.
FACTS
Petitioner Elise Quiazon is the daughter of Eliseo Quiazon and Ma. Lourdes Belen, who
are common-law partners. When Eliseo died instestate, Elise through her mother filed
a Petition for Letters of Administration before the RTC, claiming that she is a natural
child of Eliseo having conceived at the time when her parents were both capacitated to
marry each other. Filiation was proven by her Birth Certificate signed by Eliseo.
Insisting on the legal capacity of Eliseo and Lourdes, Elise impugned the validity of
Eliseo’s marriage to Amelia Garcia-Quiazon by claiming it was bigamous.
Respondent Amelia opposed the issuance of the letters of administration asserting that
the venue of the petition was improperly laid. However, the RTC rendered its decision
in favor of Elise. On appeal, the deicison was affirmed. Hence, the petition was filed
before the SC raising the argument that Elise has not shown any interest in the petition
for letters of administration and that the CA erred in declaring that Eliseo and Amelia
were no legally married because Elise has no cause of action on it.
ISSUE
Whether or not Elise has a cause of action for declaration of nullity of marriage despite
the death of his father, hence cannot be deemed as an interested party.
RULING
Yes, Elise has a cause of action. The Court ruled that in a void marriage, no marriage
has taken place and it cannot be the source of right, such that any interested party may
attach the marriage directly or collaterally without prescription, which may be filed
even beyond the lifetime of the parties to the marriage. Having successional rights that
would be prejudiced by her father’s marriage to Amelia, Elise may without a doubt
impugn the existence of such marriage even after the death of her father. The said
marriage may be questioned by filing an action attaching its validity, or collaterally by
raising it as an issue in a proceeding for the settlement of the estate of the deceased
spouse. As a compulsory heir, Elise has a cause of action for the declaration of nullity of
the void marriage of Eliseo and Amelia.
Likewise, Elise who stands to be benefited by the distribution of Eliseo’s estate is
deemed to be an interested part. An interested part is one who would be benefited in
the estate. Having a vested right in the distribution of Eliseo’s estate, Elise can
rightfully be considered as an interested party.
RULING
Petition is denied for lack of merit