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ANONUEVO VS.

INTESTATE ESTATE OF JALANDONI


636 SCRA
Topic: Intervention
Facts:
Rodolfo Jalandoni died intestate. His brother Bernardino filed petition for issuance of
letters of administration with Court of First Instance of Negros Occidental to commence the
judicial settlement of the estate. May Anonuevo and their siblings introduced themselves as
children of Sylvia Desantis, who is the daughter of Isabel Blee, who at the time of Rodolfos
death is the legal spouse of the letter. Thus, isable is entitled to a share in estate of Rodolfo.
Petitioners pray that they be allowed to intervene on behalf in the intestate proceedings
because Sylvia and Isabel have already passed away. Respondents opposed because the
evidences showed by the Petitioners revealed that Isabel has a subsisting marriage with John
Desantis at time she was purportedly married to Rodolfo. Thus, marriage with Rodolfo was void
ab initio.
The intestate court issued an order allowing petitioners to take part in settlement
proceedings. CA sided with the respondents with regard to the marriage of Isabel with John
Desantis.

Issue:
Whether CA erred when it nullified the orders of intestate court allowing Petitioners to
intervene in settlement proceedings

Ruling: NO
A courts power to allow or deny intervention, albeit discretionary in nature, is
circumscribed by the basic demand of sound judicial procedure that only a person with interest
in an action or proceeding may be allowed to intervene. Otherwise stated, a court has no
authority to allow a person, who has no interest in an action or proceeding, to intervene therein.
Petitioners and their siblings failed to offer sufficient evidence to establish that Isabel
was the legal spouse of Rodolfo. The very evidence of the petitioners and their siblings negates
their claim that Isabel has interest in Rodolfos estate. The birth certificate of Sylvia precisely
serves as the competent evidence of marriage between Isabel and John Desantis.
The inability of the petitioners and their siblings to present evidence to prove that
Isabels prior marriage was dissolved results in a failure to establish that she has interest in the
estate of Rodolfo. Clearly, an intervention by the petitioners and their siblings in the settlement
proceedings cannot be justified.