Garcia V. Belen, GR No.

189121 (2013)

FACTS:

Petitioner Elise Quiazon is the daughter of Eliseo Quiazon and Ma. Lourdes Belen, who are common-law
partners. When Eliseo died intestate, 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
decision was affirmed. Hence, the petition was filed before the SC 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.

HELD:

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.