G.R. No. 178221; December 1, 2010
MAY D. AÑONUEVO, ALEXANDER BLEE DESANTIS and JOHN DESANTIS NERI, Petitioners, vs. INTESTATE ESTATE OF RODOLFO G. JALANDONI, represented by BERNARDINO G. JALANDONI as Special Administrator, Respondent.

FACTS

Rodolfo G. Jalandoni died intestate in 1966. In 2003, petitioners, along with their siblings, sought to intervene in the ongoing estate proceedings. They claimed to be the grandchildren of Isabel Blee, whom they asserted was the legal spouse of Rodolfo at the time of his death. They presented marriage certificates between Isabel and Rodolfo. As Isabel and their mother, Sylvia, were deceased, petitioners sought to intervene to enforce Isabel’s alleged hereditary rights.
The respondent estate, represented by Rodolfo’s brother Bernardino, opposed the intervention. It contended that petitioners failed to establish Isabel’s status as a legal heir. The estate presented Sylvia’s birth certificate, which identified Sylvia as the “legitimate” child of Isabel and John Desantis and listed both parents as “married.” The respondent argued this was prima facie evidence of a prior subsisting marriage between Isabel and John Desantis, rendering her subsequent marriage to Rodolfo bigamous and void.

ISSUE

Whether the Court of Appeals erred in nullifying the trial court’s orders that allowed petitioners to intervene in the intestate proceedings.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The core legal logic centered on the requirement for intervention under Rule 19 of the Rules of Court, which mandates that an intervenor must have a legal interest in the matter in litigation. The Court held that petitioners’ claim of a legal interest was contingent upon proving that Isabel was Rodolfo’s legal spouse.
The Court ruled that the birth certificate of Sylvia constituted prima facie evidence of the facts stated therein, including the civil status of Isabel as married to John Desantis at the time of Sylvia’s birth in 1946. This presumption of a prior marriage remained unrebutted, as petitioners presented no evidence that this marriage was dissolved before Isabel’s purported marriage to Rodolfo in the 1950s. Consequently, the Isabel-Rodolfo marriage was void for bigamy. Since Isabel was not the legal spouse, she had no hereditary right to the estate. Petitioners, claiming through her, therefore failed to demonstrate the requisite legal interest to intervene in the settlement proceedings. The trial court’s allowance of intervention was thus correctly nullified for having been issued with grave abuse of discretion.