Garcia-quiason vs belen

Petitioner Elise Quiazon is the daughter of Eliseo Quiazon and Ma. Lourdes Belen, who
are common-law partners. When Eliseo died instestate, Elise through her mother filed a
Petition for Letters of Administration before the RTC, claiming that she is a natural child
of Eliseo having conceived at the time when her parents were both capacitated to marry
each other. Filiation was proven by her Birth Certificate signed by Eliseo. Insisting on the
legal capacity of Eliseo and Lourdes, Elise impugned the validity of Eliseo’s marriage to
Amelia Garcia-Quiazon by claiming it was bigamous.

Respondent Amelia opposed the issuance of the letters of administration asserting that
the venue of the petition was improperly laid. ---- However, the RTC rendered its
decision in favor of Elise. On appeal, the deicison was affirmed. Hence, the petition was
filed before the SC for review on certiorari raising the argument that Elise has not shown
any interest in the petition for letters of administration and that the CA erred in
declaring that Eliseo and Amelia were no legally married because Elise has no cause of
action on it.

ISSUE

Whether or not Elise has a cause of action for declaration of nullity of marriage despite
the death of his father, hence cannot be deemed as an interested party.

RULING

Yes, Elise has a cause of action. The Court ruled that in a void marriage, no marriage has
taken place and it cannot be the source of right, such that any interested party may
attach the marriage directly or collaterally without prescription, which may be filed even
beyond the lifetime of the parties to the marriage. Having successional rights that would
be prejudiced by her father’s marriage to Amelia, Elise may without a doubt impugn the
existence of such marriage even after the death of her father. The said marriage may be
questioned by filing an action attaching its validity, or collaterally by raising it as an issue
in a proceeding for the settlement of the estate of the deceased spouse. As a
compulsory heir, Elise has a cause of action for the declaration of nullity of the void
marriage of Eliseo and Amelia.
Likewise, Elise who stands to be benefited by the distribution of Eliseo’s estate is
deemed to be an interested part. An interested part is one who would be benefited in
the estate. Having a vested right in the distribution of Eliseo’s estate, Elise can rightfully
be considered as an interested party.

RULING

Petition is denied for lack of merit.

The petitioners opposed the issuance of the letters of administration by filing an opposition/motion to
dismiss, they asserted tha as shown by his death certificate, Eliseo was a resident of Capas Tarlac and
not of las pipnas city and tye petition of the settlement of decedents estate should have been filed in
capas not in las pinas,.

Issue:

Won the CA gravely erred in declaring that the marriage between Eliseo quiazon and Amelia Garcia-
Quiazon is void ab initio for being bigamous.