Catalan v Catalan-Lee (Conflict of Laws)

Catalan v Catalan-Lee
2012

MEROPE ENRIQUEZ VDA. DE CATALAN, Petitioner, - versus - LOUELLA A. CATALAN-LEE, Respondent.

FACTS:
Orlando B. Catalan was a naturalized American citizen. After allegedly obtaining a divorce in the United States from his first wife, Felicitas Amor, he contracted a second marriage with petitioner herein.

On 18 November 2004, Orlando died intestate in the Philippines. Thereafter, on 28 February 2005, petitioner filed with the Regional Trial Court (RTC) of Dagupan City a Petition for the issuance of letters of administration for her appointment as administratrix of the intestate estate of Orlando. Apparently, Felicitas Amor filed a Complaint for bigamy, alleging that petitioner contracted a second marriage to Orlando despite having been married to one Eusebio Bristol on 12 December 1959.

DECISION OF LOWER COURTS:
(1) RTC: acquitted petitioner of bigamy but dismissed the Petition for the issuance of letters of administration filed by petitioner and granted that of private respondent. Contrary to its findings in Crim. Case No. 2699-A, the RTC held that the marriage between petitioner and Eusebio Bristol was valid and subsisting when she married Orlando.
(2) CA: dismissed petition.

ISSUE:
Whether petitioner has standing to petition for letters of administration

RULING:
The trial court no longer required petitioner to prove the validity of Orlando’s divorce under the laws of the United States and the marriage between petitioner and the deceased. Thus, there is a need to remand the proceedings to the trial court for further reception of evidence to establish the fact of divorce.

Should petitioner prove the validity of the divorce and the subsequent marriage, she has the preferential right to be issued the letters of administration over the estate. Otherwise, letters of administration may be issued to respondent, who is undisputedly the daughter or next of kin of the deceased, in accordance with Sec. 6 of Rule 78 of the Revised Rules of Court.