G.R. No. 124862 December 22, 1998
FE D. QUITA, petitioner, vs. COURT OF APPEALS and BLANDINA DANDAN, respondents.

FACTS

Fe D. Quita and Arturo Padlan, both Filipino citizens, were married in 1941. Their marriage later deteriorated, leading Fe to obtain a divorce decree in California, USA, in 1954. She subsequently remarried twice abroad. Arturo Padlan died in 1972 in the Philippines. Blandina Dandan claimed to be Arturo’s surviving spouse, and several individuals claimed to be his children. During the settlement of Arturo’s estate, Fe moved for the immediate declaration of heirs. The trial court, citing the Tenchavez doctrine that a foreign divorce between Filipino citizens is not recognized in the Philippines, initially declared Fe and Arturo’s brother, Ruperto, as the sole intestate heirs, ruling that Fe’s marriage to Arturo subsisted until his death.
On reconsideration, the trial court modified its decision, declaring the Padlan children (except one) as heirs entitled to one-half of the estate, with Fe entitled to the other half. It excluded Blandina, finding her marriage to Arturo void due to his prior subsisting marriage to Fe. The Court of Appeals, however, nullified the trial court’s proceedings and ordered a remand, finding a violation of procedural rules. It held that a controversy existed regarding the lawful heirs, which under the Rules of Court requires a full hearing.

ISSUE

Whether the Court of Appeals correctly ordered the remand of the case to the trial court for further proceedings.

RULING

Yes, the Supreme Court affirmed the remand. The Court agreed that no factual controversy existed regarding the hereditary rights of the acknowledged Padlan children, whose shares were already determined. However, a genuine controversy persisted regarding the legitimate surviving spouse of Arturo Padlan. This central issue—whether Fe D. Quita remained the legal spouse entitled to inherit—was a mixed question of law and fact requiring a full-blown trial. The trial court’s summary proceeding, based merely on the submission of documents without a formal hearing where Fe could present evidence on the validity and effects of the foreign divorce, was procedurally infirm. Section 1, Rule 90 of the Rules of Court mandates that such controversies “shall be heard and decided as in ordinary cases.” The remand was thus proper to allow Fe a full opportunity to substantiate her claim as the surviving spouse through the reception of evidence, limited strictly to that specific issue. The Court emphasized that the established rights of the acknowledged children were not to be relitigated.