Edgar San Luis v. Felicidad San Luis

Summary

This consolidated case involved the estate settlement of former Laguna Governor Felicisimo San Luis, whose children from his first marriage challenged his third wife Felicidad's legal capacity to file for letters of administration. The key issues were proper venue and the validity of Felicidad's marriage following Felicisimo's divorce from his American second wife. The Supreme Court established that for estate settlement purposes, 'residence' means actual physical habitation rather than legal domicile, affirming Makati as proper venue since Felicisimo maintained a residence in Alabang. The Court also reinforced the Van Dorn doctrine, recognizing that Filipino spouses gain capacity to remarry when validly divorced by alien spouses abroad, even under the Civil Code. However, the case was remanded for additional evidence to properly authenticate the foreign divorce decree and marriage certificate under Rules of Court requirements. The decision significantly clarified venue rules for estate proceedings and strengthened recognition of foreign divorces involving Filipino citizens.