AONUEVO VS.

JALANDONI

Rodolfo G. Jalandoni (Rodolfo) died intestate,childless. His brother (Bernardino)filed before the RTCa
petitionfor the issuance of letters of administration and to commence judicial settlement of the decedents
estate. During the pendency of the case,Aonuevo and her siblings intervened. They said their mother
Sylvia was daughter of Isabel and John Dessantis. But at the time of Rodolfos death, their grandmother
was his lawful wife based on a marriage certificate they presented. Bernardino opposed the intervention
and alleged that prior the marriage of Rodolfo to Isabel, John and Isabel were already married as shown in
the birth certificate of Sylvia which states that she was a "legitimate" child of Isabel and John Desantis.
The document also certifies the status of both Isabel and John Desantis as "married. And therefore the
marriage of Rodolfo and Isabel was void ab initio.However,The intestate court held that the birth
certificate of Sylvia was insufficient to prove that there was a previous marriage between Isabel and John
Desantis.The decision of the trial court was reversed by CA. The petitioners on their appeal contend that
the Bernardino was not able to produce any marriage certificate executed between Isabel and John
Desantis and the conspicuous absence of such certificate can, in turn, only lend credibility to the position
that no such marriage ever took place.

ISSUE: Whether or not the marriage between Rodolfo and Isabel was valid?
ISSUE: Whether or not Anonuevo and her siblings can intervene in the settlement of the decedents state?
HELD:
NO. Because the evidence presented by the petitioners and their siblings themselves which, properly
appreciated, supports the finding that Isabel was, indeed, previously married to John Desantis.
Consequently, in the absence of any proof that such marriage had been dissolved by the time Isabel was
married to Rodolfo, the inescapable conclusion is that the latter marriage is bigamous and, therefore,
void ab initio. While a marriage certificate is considered the primary evidence of a marital union, it is not
regarded as the sole and exclusive evidence of marriage. Jurisprudence teaches that the fact of marriage
may be proven by relevant evidence other than the marriage certificate. Hence, even a person's birth
certificate may be recognized as competent evidence of the marriage between his parents.
NO. They have no personal standing to intervene. The birth certificate of Sylvia which shows that Isabel
and John Dessantis were married is sufficient proof that indeed they were married. Therefore Isabels
marriage with Rodolfo is void since as that time Isabel was married to John. Being not married to
Rodolfo, Isabel and her descendants have no share in the Estate of Rodolfo.