Yao Kee, Sze Sook Wah, Sze Lai Cho, and Sy Chun Yen v. Aida Sy-Gonzales, Manuel Sy, Teresita Sy-Bernabe, Rodolfo Sy, and Honorable Court of Appeals
REITERATIONFacts
The Antecedents: Sy Kiat, a Chinese national, died intestate in Caloocan City, leaving properties worth P300,000.00. Aida Sy-Gonzales and others (private respondents) filed a petition for letters of administration, claiming to be Sy Kiat's children with Asuncion Gillego and questioning Sy Kiat's marriage to Yao Kee and the filiation of Yao Kee's children. Yao Kee and her children (petitioners) opposed, asserting Yao Kee was Sy Kiat's lawful wife married in China and that their children were legitimate. The trial court found Sy Kiat legally married to Yao Kee and their children legitimate, while Aida Sy-Gonzales and others were acknowledged illegitimate offspring. Sze Sook Wah was appointed administratrix. Procedural History: On appeal, the Court of Appeals modified the trial court's decision. It declared Aida Sy-Gonzales and others as acknowledged natural children with Asuncion Gillego, and Sze Sook Wah and others as acknowledged natural children with Yao Kee, finding the marriage of Sy Kiat to Yao Kee unproven as valid under Chinese law. The CA also declared a deed of sale by Sy Kiat valid, excluding the property from the estate, and affirmed Sze Sook Wah's appointment as administratrix. Both parties moved for reconsideration, which was denied. Appeals were filed with the Supreme Court. The Petition: The instant petition questioned paragraphs (1) and (2) of the CA's dispositive portion, specifically the declaration of the marriage between Sy Kiat and Yao Kee as unproven and the classification of Aida Sy-Gonzales and others as natural children. Petitioners argued that the marriage was proven validly under Chinese law and custom, and that issues of paternity and filiation should have been heard by the Juvenile and Domestic Relations Court.
Issue(s)
Whether the marriage between Sy Kiat and Yao Kee was proven valid in accordance with the laws of the People's Republic of China. Whether Aida Sy-Gonzales, Manuel Sy, Teresita Sy-Bernabe, and Rodolfo Sy are acknowledged natural children of Sy Kiat with Asuncion Gillego. Whether the questions on the validity of Sy Kiat's marriage to Yao Kee and the paternity/filiation of the parties should have been ventilated in the Juvenile and Domestic Relations Court.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. It held that the marriage between Sy Kiat and Yao Kee was not proven to be valid under Chinese law, and thus, their children could only be considered acknowledged natural children. The Court also affirmed the status of Aida Sy-Gonzales and others as acknowledged natural children of Sy Kiat with Asuncion Gillego. The issue of jurisdiction was rendered moot by the abolition of the Juvenile and Domestic Relations Courts and the vesting of their functions in the Regional Trial Courts, and by the rule that incidents arising in ordinary courts should be determined in the main case.
Ratio Decidendi
On the validity of the marriage between Sy Kiat and Yao Kee: The Court held that while the fact of marriage was proven through testimonies and documents (Sy Kiat's Master Card of Registered Alien, Alien Certificate of Registration, and a certification from the Embassy of the People's Republic of China), these did not suffice to establish the validity of the marriage according to Chinese law or custom. Petitioners failed to present competent evidence of Chinese law on marriage, as required by Article 71 of the Civil Code and established jurisprudence. The testimonies of Yao Kee and Gan Ching were not considered proof of Chinese law, and the Court cannot take judicial notice of foreign laws. The presumption that foreign law is the same as Philippine law applied, and since the marriage lacked a solemnizing officer, it was not valid under Philippine law. Therefore, the marriage could not be recognized in the Philippines. On the status of Aida Sy-Gonzales, Manuel Sy, Teresita Sy-Bernabe, and Rodolfo Sy: The Court affirmed their status as acknowledged natural children of Sy Kiat with Asuncion Gillego. This was based on Sy Kiat's acknowledgment through a compromise agreement approved by the Court of First Instance, wherein he recognized them as his children with Asuncion Gillego and made provisions for their inheritance. This compromise agreement served as a voluntary acknowledgment before a court of record. On the jurisdiction of the Juvenile and Domestic Relations Court: The Court noted that even if the Juvenile and Domestic Relations Court had exclusive jurisdiction over paternity and acknowledgment cases, any such question arising as an incident in a main case pending in an ordinary court should be determined in the main case. This rule prevents multiplicity of suits and conflicting rulings. Furthermore, with the enactment of Batas Pambansa Blg. 129, the Juvenile and Domestic Relations Courts were abolished, and their functions were vested in the Regional Trial Courts. Therefore, the issue of jurisdiction was rendered moot.
Main Doctrine
The validity of a foreign marriage must be proven by presenting competent evidence of the foreign law and convincing evidence of the marriage itself. In the absence of such proof, the marriage cannot be recognized in the Philippines, and the children born thereof are considered acknowledged natural children.