Alfelor vs. Halasan

A judicial admission of a prior marriage made in a pleading or during trial dispenses with further proof of that marriage and establishes the legal interest necessary to allow intervention in a partition case.

Heirs of the late spouses Telesforo and Cecilia Alfelor filed a complaint for partition before the Regional Trial Court of Davao City. Among the plaintiffs were Teresita Sorongon and her children, Joshua and Maria Katrina, who claimed to be the surviving spouse and legitimate children of Jose Alfelor, one of the children of the deceased Alfelor spouses. Respondent Josefina Halasan moved to intervene, alleging she was the first wife of Jose Alfelor and his primary compulsory heir, rendering the subsequent marriage of Jose to Teresita void ab initio.

• The Partition Suit and Claim of Heirship: The children and heirs of the late spouses Telesforo and Cecilia Alfelor filed a complaint for partition. Among the plaintiffs were Teresita Sorongon and her children, Joshua and Maria Katrina, who claimed to be the surviving spouse and legitimate children of Jose Alfelor, a child of the deceased Alfelor spouses.
• Motion for Intervention: Respondent Josefina Halasan filed a motion to intervene, alleging she was the surviving spouse and primary compulsory heir of Jose Alfelor. She claimed her marriage to Jose on February 1, 1956 rendered his subsequent marriage to Teresita void ab initio. She attached a machine copy of her marriage contract to her pleading.
• RTC Proceedings: Josefina failed to appear in court to testify or present witnesses to identify the marriage contract. Teresita testified that she knew of Jose's previous marriage to Josefina but married Jose anyway in 1966, believing in good faith that Jose had the right to remarry because Josefina had been absent for more than seven years. Teresita's relatives even served as secondary sponsors at her wedding to Jose.
• RTC Dismissal of Intervention: The RTC denied the motion for intervention and dismissed the complaint-in-intervention. The trial court found that Josefina failed to prove her claim by preponderance of evidence due to her absence and the lack of proper identification of the marriage contract. The RTC declared Teresita and her children as the legal and legitimate heirs of Jose Alfelor based on Teresita's good faith and Jose's representation of his children in his Statement of Assets and Liabilities.
• CA Reversal: The Court of Appeals reversed the RTC, ruling that Teresita's admission of the first marriage in her Reply-in-Intervention and testimony constituted a judicial admission that required no further proof. The CA ordered the RTC to admit the complaint-in-intervention.

• Hearsay: Petitioners argued that Teresita's admission of the first marriage was based merely on what was told to her by other persons, rendering it hearsay and without probative value.
• Palpable Mistake: Petitioners maintained that judicial admissions may be contradicted by showing they were made through palpable mistake.
• Insufficient Proof: Petitioners asserted that Josefina failed to appear in court to substantiate her complaint-in-intervention and only submitted a machine copy of the marriage contract without proper identification, which cannot be equated to proof of validity.

• Judicial Admission: Respondent countered that the matters involved fall under Section 4, Rule 129 of the Revised Rules of Court, qualifying as a judicial admission that does not require proof. The CA committed no error in ruling in her favor based on this admission.

• Intervention: Whether the first wife of a decedent, a fact admitted by the other party claiming to be the second wife, should be allowed to intervene in an action for partition involving the share of the deceased husband in the estate of his parents.

• Intervention: The intervention was properly allowed. Teresita's admission in her Reply-in-Intervention that she knew of the previous marriage, and her subsequent testimony reaffirming this knowledge, constituted a deliberate, clear, and unequivocal judicial admission. Judicial admissions remove an admitted fact from the field of controversy and dispense with further proof. Because the first marriage was admitted, Josefina demonstrated a legal interest in the partition case, satisfying the requirements for intervention under Section 1, Rule 19 of the Revised Rules of Court.

• Judicial Admissions — A deliberate, clear, and unequivocal statement made in the course of judicial proceedings qualifies as a judicial admission. It is a waiver of proof, removes the admitted fact from the field of controversy, and is conclusive upon the party making it. It cannot be controverted by the party making the admission, and contrary or inconsistent proofs submitted by that party should be ignored whether objection is interposed or not.
• Intervention — A person may intervene when they have (1) a legal interest in the matter in litigation; (2) an interest in the success of any of the parties; (3) an interest against the parties; or (4) is so situated as to be adversely affected by a distribution or disposition of property in the custody of the court. The interest must be direct and immediate, such that the intervenor will gain or lose by the direct legal operation and effect of the judgment.

• "A party who judicially admits a fact cannot later challenge that fact as judicial admissions are a waiver of proof; production of evidence is dispensed with."
• "An admission made in the pleadings cannot be controverted by the party making such admission and are conclusive as to such party, and all proofs to the contrary or inconsistent therewith should be ignored, whether objection is interposed by the party or not."

• Sarmiento v. Court of Appeals, G.R. No. 96740 — Distinguished. The Court clarified that Sarmiento resolved the validity of a marriage and the legitimacy of heirs, not the propriety of allowing a motion for intervention.
• Santiago v. De los Santos, G.R. No. L-20241 — Followed. Cited for the rule that an admission made in a pleading cannot be controverted by the party making such admission and is conclusive as to such party.
• Nordic Asia Ltd. v. Court of Appeals, 451 Phil. 482 (2003) — Followed. Cited for the definition of the legal interest required for intervention, which must be direct and immediate such that the intervenor will gain or lose by the direct legal operation and effect of the judgment.
• Uy v. Court of Appeals, G.R. No. 102726 — Followed. Cited for allowing a surviving legal spouse and legitimate child to intervene in intestate proceedings even after a compromise agreement, emphasizing that their inclusion is essential for the proper disposition of the case.
• Elayda v. Court of Appeals, G.R. No. 49327 — Followed. Cited for the principle that judicial admissions are conclusive and inconsistent proofs should be ignored.
• Cunanan v. Amparo, 80 Phil. 227 (1948) — Followed. Cited for the rule that allegations, statements, or admissions contained in a pleading are conclusive as against the pleader.

• Section 4, Rule 129, Revised Rules of Court — Provides that an admission does not require proof. Applied to hold that Teresita's admission of the first marriage in her pleading and testimony dispensed with the need for further proof of Josefina's marriage to Jose.
• Section 1, Rule 19, Revised Rules of Court — Enumerates who may intervene. Applied to determine that Josefina, as the admitted first wife, possessed the requisite legal interest in the matter in litigation to intervene in the partition case.

Artemio V. Panganiban (CJ), Consuelo Ynares-Santiago, Ma. Alicia Austria-Martinez, Minita V. Chico-Nazario