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Quita Vs Court of Appeals

Fe D. Quita and Arturo Padlan were married in the Philippines but later divorced in the United States in 1954. Both parties remarried. When Arturo died in 1972, the court had to determine who the legal heirs were. The trial court initially ruled that Quita was still considered Arturo's spouse since their divorce was not valid in the Philippines. However, the Court of Appeals noted that Quita was an American citizen at the time of the divorce, making it valid according to her national laws. Therefore, Quita could no longer be recognized as Arturo's surviving spouse or primary beneficiary. The marriage between Arturo and his second wife, Blandina, was also ruled valid, entitling

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79 views2 pages

Quita Vs Court of Appeals

Fe D. Quita and Arturo Padlan were married in the Philippines but later divorced in the United States in 1954. Both parties remarried. When Arturo died in 1972, the court had to determine who the legal heirs were. The trial court initially ruled that Quita was still considered Arturo's spouse since their divorce was not valid in the Philippines. However, the Court of Appeals noted that Quita was an American citizen at the time of the divorce, making it valid according to her national laws. Therefore, Quita could no longer be recognized as Arturo's surviving spouse or primary beneficiary. The marriage between Arturo and his second wife, Blandina, was also ruled valid, entitling

Uploaded by

Crisvon L. Gazo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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QUITA VS COURT OF APPEALS

GR. 124862 December 22, 1998

FACTS:

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
thatthe case was decided without a hearing in violation of the Rules of Court.

ISSUE:

(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.

RULING:

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

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