De Santis vs.

Jalandoni

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:

Whether or not the marriage of Rodolfo and Isabel 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.