G.R. No. 132524 December 29, 1998
FEDERICO C. SUNTAY, petitioner, vs. ISABEL COJUANGCO-SUNTAY and HON. GREGORIO S. SAMPAGA, Presiding Judge, Branch 78, Regional Trial Court, Malolos, Bulacan, Respondents.

FACTS

The case involves the settlement of the intestate estate of Cristina Aguinaldo-Suntay. Respondent Isabel Cojuangco-Suntay, a granddaughter of the decedent, filed a petition for her appointment as administratrix. Petitioner Federico C. Suntay, the surviving spouse of the decedent, opposed the petition and later moved to dismiss it. His primary argument was that Isabel is an illegitimate child and thus barred from inheriting from her paternal grandmother by right of representation under Article 992 of the Civil Code. This claim of illegitimacy was based on a 1967 Court of First Instance (CFI) decision in a legal separation case filed by Isabel’s father, Emilio Aguinaldo Suntay, against Isabel’s mother. The dispositive portion (fallo) of that CFI decision declared the marriage of Isabel’s parents “null and void.”

ISSUE

The core issue is whether the respondent, Isabel Cojuangco-Suntay, is a legitimate child entitled to inherit by right of representation from her grandmother. This hinges on the correct interpretation of the 1967 CFI decision that declared her parents’ marriage “null and void.” Specifically, the Court must resolve whether the fallo (dispositive portion) or the ratio decidendi (body of the decision explaining the legal basis) of that prior judgment controls in determining the nature of Isabel’s filiation.

RULING

The Supreme Court ruled in favor of respondent Isabel Cojuangco-Suntay, holding that she is a legitimate child. The Court emphasized that when there is a conflict between the fallo and the ratio decidendi of a decision, the latter prevails. The fallo must find support from the decision’s reasoning and conclusions. An examination of the 1967 CFI decision reveals that the court based its declaration of nullity on Article 85(3) of the Civil Code, which pertains to annulment due to either party being of unsound mind at the time of marriage. A marriage annulled under this ground is voidable, not void ab initio. The CFI’s use of the term “null and void” in the fallo was a procedural inaccuracy. Under the law, a voidable marriage is valid until annulled, and children conceived or born before its annulment are legitimate. Therefore, the ratio decidendi of the CFI decision established that the marriage was merely voidable, and consequently, Isabel remained a legitimate child. Since she is legitimate, Article 992 of the Civil Code, which bars illegitimate children from representing their parent in the succession of the latter’s legitimate relatives, does not apply. She has the right to succeed her predeceased father by representation in her grandmother’s estate. The trial court did not commit grave abuse of discretion in denying the motion to dismiss.