Quita vs. CA (Digested)

Fe D. Quita, Petitioner,
vs.
Court of Appeals and Blandina Dandan, Respondents.
Facts:
Fe D. Quita, the petitioner, and Arturo T. Padlan, both Filipinos, were married
inthe Philippines on May 18, 1941. They got divorce in San Francisco on July 23,
1954.Both of them remarried another person. Arturo remarried Blandina 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
whowill 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. Romillo 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.
Issue:
Whether or not Blandina’s marriage to Arturo void ab initio.

Held:
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.