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    Casedigestno18 GR133743 134029

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    Eric Recomendable
    Felicisimo T. San Luis had three marriages throughout his life. After his death, his third wife Felicidad San Luis filed a petition for letters of administration to settle Felicisimo's estate. Edgar San Luis, a son from Felicisimo's first marriage, argued the venue was improper and Felicidad lacked legal capacity. The Supreme Court ruled the venue was proper as Felicisimo resided in Muntinlupa with Felicidad, and Felicidad had legal capacity as she co-owned properties acquired through their cohabitation, even if the marriage was not valid.

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    Casedigestno18 GR133743 134029

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    Eric Recomendable
    59 views1 page
    Felicisimo T. San Luis had three marriages throughout his life. After his death, his third wife Felicidad San Luis filed a petition for letters of administration to settle Felicisimo's estate. Edgar San Luis, a son from Felicisimo's first marriage, argued the venue was improper and Felicidad lacked legal capacity. The Supreme Court ruled the venue was proper as Felicisimo resided in Muntinlupa with Felicidad, and Felicidad had legal capacity as she co-owned properties acquired through their cohabitation, even if the marriage was not valid.

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    Felicisimo T. San Luis had three marriages throughout his life. After his death, his third wife Felicidad San Luis filed a petition for letters of administration to settle Felicisimo's estate. Edgar San Luis, a son from Felicisimo's first marriage, argued the venue was improper and Felicidad lacked legal capacity. The Supreme Court ruled the venue was proper as Felicisimo resided in Muntinlupa with Felicidad, and Felicidad had legal capacity as she co-owned properties acquired through their cohabitation, even if the marriage was not valid.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    59 views1 page

    Casedigestno18 GR133743 134029

    Uploaded by

    Eric Recomendable
    Felicisimo T. San Luis had three marriages throughout his life. After his death, his third wife Felicidad San Luis filed a petition for letters of administration to settle Felicisimo's estate. Edgar San Luis, a son from Felicisimo's first marriage, argued the venue was improper and Felicidad lacked legal capacity. The Supreme Court ruled the venue was proper as Felicisimo resided in Muntinlupa with Felicidad, and Felicidad had legal capacity as she co-owned properties acquired through their cohabitation, even if the marriage was not valid.

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    © All Rights Reserved
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    CASE DIGEST NO.

    18

    G.R. No. 133743


    February 6, 2007
    EDGAR SAN LUIS, petitioner,
    vs
    FELICIDAD SAN LUIS, Respondent.
    _____________________________

    G.R. No. 134029


    February 6, 2007
    EDGAR SAN LUIS, petitioner,
    vs
    FELICIDAD SAGALONGOS alias FELICIDAD SAN LUIS, Respondent.

    FACTS OF THE CASE:


    Felicisimo T. San Luis who was the former Governor of the Province of Laguna during his lifetime
    contracted three marriages. His first marriage was with Virginia Sulit to which he had six children namely
    Rodolfo, Mila, Edgar, Linda, Emilita, and Manuel. Five years later, he married Merry Lee Corwin an
    American citizen, with whom he had son, Tobias. However, Merry Lee filed a Complaint for Divorce
    before the Family Court of First Circuit, State of Hawaii, United States of America (USA), which issued a
    Decreee Granting Absolute Divorce and Awarding Child Custody.
    Felicisimo married respondent Felicidad San Luis, then surnamed Sagalongos at Wilshire
    Boulevard, Los Angeles, California, USA. He had no children with respondent but lived with her for 18
    years from the time of their marriage up to his death. Thereafter, respondent sought the dissolution of
    their conjugal partnership assets and the settlement of Felicisimo’s estate which she filed a petition of
    letter of administration before the Regional Court of Makati City.
    ISSUE:
    1. Whether the venue was properly laid, and;
    2. Whether respondent has legal capacity to file the subject petition of letter of administration.
    RULING:
    Yes, the venue was properly laid. The supreme court says for purposes of fixing the venue of
    settlement of estate of Felisicimo, the “residence” of a person is his personal, actual or physical
    habitation, or actual residence or place of abode, which may not necessarily be his legal residence or
    domicile provided he resides therein with continuity and consistency. Hence, it is possible that a person
    may have his residence in one place and domicile in another. There is a distinction between “residence”
    for purposes of election laws and “residence” for purposes of fixing the venue of actions. At that time,
    Muntinlupa was still a municipality and the branches of Regional Trial Court of the National Capital
    Judicial region which had territorial jurisdiction over Muntinlupa were then seated in Makati City as per
    Supreme Court Administrative Order No. 3. Thus, the subject petition was validly filed before the RTC of
    Makati City.
    Yes, the respondent has legal capacity to file the subject petition for letters of administration.
    Even assuming that Felisicimo was not capacitated to marry respondent, she may be considered co-
    owner of Felisicimo as regards the properties that were acquired through their joint efforts during their
    cohabitation.

    Eric M. Recomendable
    Arellano University School of Law

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