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Quita vs Court of Appeals

December 22, 1998

Fact of the Case:

Fe D. Quita, the petitioner, and Arturo T. Padlan, both Filipinos, were married in
the Philippines on May 18, 1941. They got divorce in San Francisco on July 23, 1954.
Both of them remarried another person. Arturo remarried Bladina Dandan, the respondent
herewith. They were blessed with six children.
On April 16, 1972, when Arturo died, the trial court was set to declared as to who
will be the intestate heirs. The trial court invoking Tenchavez vs Escano case held that
the divorce acquired by the petitioner is not recognized in our country. Private respondent
stressed that the citizenship of petitioner was relevant in the light of the ruling in Van
Dorn v. Rommillo Jr that aliens who obtain divorce abroad are recognized in the
Philippnes provided they are valid according to their national law. The petitioner herself
answered that she was an American citizen since 1954. Through the hearing she also
stated that Arturo was a Filipino at the time she obtained the divorce. Implying the she
was no longer a Filipino citizen.
The Trial court disregarded the respondent’s statement. The net hereditary estate
was ordered in favor the Fe D. Quita and Ruperto, the brother of Arturo. Blandina and the
Padlan children moved for reconsideration. On February 15, 1988 partial reconsideration
was granted declaring the Padlan children, with the exception of Alexis, entitled to one-
half of the estate to the exclusion of Ruperto Padlan, and the other half to Fe Quita.
Private respondent was not declared an heir for her marriage to Arturo was declared void
since it was celebrated during the existence of his previous marriage to petitioner.
Blandina and her children appeal to the Court of Appeals that the case was decided
without a hearing in violation of the Rules of Court.

(1) Whether or not Blandina’s marriage to Arturo void ab initio.
(2) Whether or not Fe D. Quita be declared the primary beneficiary as
surviving spouse of Arturo.

No. The marriage of Blandina and Arturo is not void. The citizenship of Fe D.
Quita at the time of their divorce is relevant to this case. The divorce is valid here since
she was already an alien at the time she obtained divorce, and such is valid in their
country’s national law.
Thus, Fe D. Quita is no longer recognized as a wife of Arturo. She cannot be the
primary beneficiary or will be recognized as surviving spouse of Arturo.