De Santis v.Intestate Estate Jalandoni, December 1, 2010

FACTS: Rodolfo Jalandoni died intestate. His brother, Bernardino Jalandoni filed with RTC a petition for issuance of letters of administration. Anonuevo et al intervened and claimed that their mother Sylvia De Santis was daughter of Isabel and John. They alleged that at the time of Rodolfo’s death, their grandmother Isabel was the lawful wife of Rodolfo based on a marriage certificate. Rodolfo’s brother opposed asserting that the birth certificate of Sylvia states that Isabel and John were married, hence, Isabel and Rodolfo’s marriage was null and void. Petitioners argued that the entries in the birth certificate of Sylvia could not be used as proof that Isabel and John were indeed married.

ISSUE: W/N the marriage of Isabel and Rodolfo was valid

HELD: No. The birth certificate of Sylvia which indicates that Isabel and John were married is sufficient proof that indeed they were married. Therefore Isabel’s marriage to Rodolfo is void because at that time, she was still married to John. Consequently, her descendants have no share in the estate of Rodolfo. 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.