The Supreme Court clarified the evidentiary requirements for proving marriage in inheritance disputes, particularly concerning the admissibility of church-issued marriage contracts. The Court held that a church-issued marriage contract, or Contrato Matrimonial, is considered a private document and requires proper authentication to be admitted as evidence of marriage. This means that individuals seeking to establish marital status for inheritance purposes must provide additional evidence to support the authenticity and validity of such documents, impacting how families prove relationships in property disputes.

Lost in Time: Can a Decades-Old Marriage Contract Secure Inheritance Rights?

This case revolves around a dispute over the estate of the deceased Vicente Cercado, Sr., and his relationship with two women: Benita Castillo and Leonora Ditablan. Simplicia Cercado-Siga and Ligaya Cercado-Belison, claiming to be Vicente’s legitimate children with Benita, challenged the extrajudicial settlement of Vicente’s estate with Leonora, arguing that Vicente and Leonora’s marriage was invalid due to Vicente’s prior existing marriage with their mother, Benita. The core legal question is whether the Contrato Matrimonial (marriage contract) presented by Simplicia and Ligaya is sufficient to prove the marriage between Vicente and Benita, thereby establishing their rights to inherit from Vicente’s estate.

To prove the marriage between Vicente and Benita, Simplicia and Ligaya presented a marriage contract issued by the Iglesia Filipina Independiente. They also submitted certifications from the church acknowledging the original marriage contract and certifications of non-production of birth records from the Municipal Civil Registrar of Pililla, Rizal. Additionally, they offered a certificate of baptism for Simplicia and a joint affidavit from two disinterested persons attesting to Ligaya’s parentage. Vicente Cercado, Jr., Manuela C. Arabit, Lolita Basco, Maria C. Aralar, and Violeta C. Binadas, the respondents, countered by asserting their legitimacy as heirs of Vicente and Leonora, presenting their own marriage certificate as evidence. They also challenged the validity of the marriage between Vicente and Benita, questioning the authenticity of the presented documents and claiming that the petitioners failed to prove their filiation to Vicente.

The Regional Trial Court (RTC) initially ruled in favor of Simplicia and Ligaya, declaring the extrajudicial settlement of the estate null and void. The RTC based its decision on the validity of the marriage between Vicente and Benita, as evidenced by the Contrato Matrimonial. However, the Court of Appeals (CA) reversed this decision, finding that the Contrato Matrimonial, being a private document, was not properly authenticated and therefore inadmissible as evidence. The CA also disregarded the baptismal certificate and joint affidavit presented by the petitioners, citing that they did not conclusively prove filiation. Aggrieved, Simplicia and Ligaya elevated the case to the Supreme Court, arguing that the Contrato Matrimonial should be considered a public document or, at the very least, an ancient document exempt from authentication requirements.

The Supreme Court affirmed the Court of Appeals’ decision, reiterating the principle that church registries of marriages are considered private documents. The Court emphasized that under Section 20, Rule 132 of the Rules of Court, a private document must be authenticated before it can be admitted as evidence. This authentication requires testimony from someone who witnessed the execution of the document, can identify the signatures, or to whom the parties have confessed its execution. In this case, Simplicia, who presented the marriage contract, could not authenticate it because she was not present during its execution and could not verify the signatures, reinforcing the need for proper authentication of private documents.

“Under Section 20, Rule 132, Rules of Court, before a private document is admitted in evidence, it must be authenticated either by the person who executed it, the person before whom its execution was acknowledged, any person who was present and saw it executed, or who after its execution, saw it and recognized the signatures, or the person to whom the parties to the instruments had previously confessed execution thereof.”

The petitioners also argued that the Contrato Matrimonial should be considered an “ancient document,” which, under Section 21, Rule 132, does not require authentication. An ancient document is defined as one that is more than 30 years old, produced from proper custody, and free from any alterations or suspicious circumstances. While the marriage contract met the age requirement and appeared unaltered, the Supreme Court found that it was not produced from proper custody. Proper custody requires that the document come from a place where it would naturally be found if genuine. Because Simplicia failed to conclusively prove her filiation to Vicente and Benita, she could not be considered the proper custodian of the marriage contract, making it inadmissible as an ancient document.

The Supreme Court also addressed the petitioners’ argument that the respondents’ parents’ marriage should be considered bigamous, which would invalidate the extrajudicial settlement. The Court acknowledged the principle that a bigamous marriage can be collaterally attacked. However, because the petitioners failed to adequately prove the existence and validity of the prior marriage between Vicente and Benita, the argument of bigamy could not be sustained. Consequently, the Court upheld the validity of the extrajudicial settlement of the estate between Vicente and Leonora, as the petitioners failed to establish their claim as legitimate heirs through sufficient and admissible evidence.

This case highlights the critical importance of adhering to the rules of evidence when attempting to prove marital status for inheritance purposes. The inadmissibility of the Contrato Matrimonial due to lack of authentication underscores the necessity of presenting reliable and properly authenticated documents to support claims of filiation and marital relationships. Litigants should ensure that private documents, such as church-issued marriage contracts, are properly authenticated through qualified witnesses or other admissible evidence to avoid their exclusion from consideration by the courts.

FAQs

What was the key issue in this case?	The key issue was whether the petitioners, Simplicia and Ligaya, could prove the marriage between their alleged parents, Vicente and Benita, using a church-issued marriage contract (Contrato Matrimonial) and other related documents to challenge the extrajudicial settlement of Vicente’s estate with Leonora.
Why was the Contrato Matrimonial not admitted as evidence?	The Contrato Matrimonial was deemed a private document and was not properly authenticated as required by the Rules of Court, meaning no witness testified to its execution or the genuineness of the signatures.
What makes a document an “ancient document” and why didn’t the marriage contract qualify?	An ancient document is one that is over 30 years old, produced from proper custody, and free from suspicion. The marriage contract met the age requirement, but the petitioners failed to prove they were the proper custodians as legitimate heirs.
What is “proper custody” in the context of ancient documents?	“Proper custody” means the document is found in a place where it would naturally be expected to be if it were genuine, typically with someone who has a legitimate claim to possess it, such as an heir.
What other evidence did the petitioners present, and why was it insufficient?	The petitioners presented a baptismal certificate, a joint affidavit, and certifications of non-production of birth records. These were insufficient because the baptismal certificate didn’t prove filiation, the affidavit was hearsay, and the lack of birth records didn’t confirm parentage.
What is the significance of a document being classified as “private” versus “public”?	Public documents are admissible as evidence without further proof of authenticity, whereas private documents require authentication to verify their genuineness and execution.
Can a marriage be proven solely through a church-issued certificate?	No, church-issued certificates are considered private documents and require authentication. Additional evidence, such as testimonies or public records, is typically needed to corroborate the marriage.
What was the court’s ruling on the claim of bigamy?	The court did not rule on the bigamy claim because the petitioners failed to sufficiently prove the existence and validity of the prior marriage between Vicente and Benita.
What is collateral attack in legal terms?	Collateral attack refers to challenging the validity of a judgment or decision in a proceeding that is not directly intended to overturn that judgment.

In conclusion, this case emphasizes the importance of adhering to the rules of evidence, particularly in proving filiation and marital status for inheritance claims. The Supreme Court’s decision underscores that private documents, such as church-issued marriage contracts, require proper authentication and cannot be solely relied upon to establish legal relationships.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SIMPLICIA CERCADO-SIGA VS. VICENTE CERCADO, JR., G.R. No. 185374, March 11, 2015