Case Digest (G.R. No. 124118)
Facts:
The case involves petitioners Renato, Leticia, Imelda, Alicia, Ligaya, and Zenaida Adriano, who are the children of Lucio Adriano and Vicenta Villa, and respondents Celestina, Manolo, and Aida Adriano, the children of Lucio and his first wife, Gliceria Dorado. Lucio Adriano, also known as Ambrocio Adriano, married Gliceria on October 29, 1933, and they had three children together. However, they separated around 1942, and Gliceria passed away on June 11, 1968. Lucio then cohabited with Vicenta Villa, with whom he had eight children, including the petitioners. Lucio married Vicenta on November 22, 1968, shortly after Gliceria's death. Lucio and Vicenta lived in Candelaria, Quezon, until their separation in 1972.
On October 10, 1980, Lucio executed a last will and testament, bequeathing his properties to both his children from his first and second marriages. After Lucio's death on February 11, 1981, Celestina filed for the probate of the will, which was allowed by the...
Case Digest (G.R. No. 124118)
Facts:
- Lucio Adriano, also known as Ambrocio Adriano, was married to Gliceria Dorado on October 29, 1933, and together they had three children: Celestina, Manolo, and Aida (private respondents).
- Prior to or in 1942, Lucio and Gliceria separated, with Gliceria eventually residing in Rizal, Laguna where she died on June 11, 1968.
- Around the same period, Lucio cohabited with Vicenta Villa, and their union produced eight children: Marino, Renato, Leticia, Imelda, Maria Alicia, Ligaya, Jose Vergel, and Zenaida (all petitioners except for the deceased Jose Vergel).
- Lucio later formalized his relationship with Vicenta by marrying her on November 22, 1968, about five months after Gliceria’s death.
- From 1968 until their separation in 1972, Lucio, Vicenta, and their children lived in Candelaria, Quezon.
Background of the Testator and Family Relationships
- On October 10, 1980, Lucio executed his last will and testament, which disposed of all his properties.
- The will specifically provided for:
- Bequeathing a 45,000-square meter lot with attached residential house, rice mill, warehouse, and equipment situated in Candelaria, Quezon (registered under TCT No. T-56553).
- Allocating 10,000 square meters of the property, including the warehouse, rice mill, and equipment, to the children from his first marriage (private respondents).
- Assigning the remaining 35,000 square meters to Vicenta and his children by his second marriage (petitioners).
- Bequeathing the residential house to the children by his first marriage.
- Lucio died on February 11, 1981, and Celestina Adriano, designated as the executrix in the will, initiated probate proceedings (Spec. Proc. No. 4442) on February 18, 1981 before the RTC of Lucena City.
- Despite Vicenta having opposed the probate, the RTC allowed it and issued letters testamentary to Celestina in an order dated August 22, 1983, an order later affirmed by the Intermediate Appellate Court after Vicenta’s appeal.
Execution and Probate of the Last Will and Testament
- Prior to the probate, Vicenta had instituted a separate complaint (Civil Case No. 7534) for provisional partition or separation of properties pendente lite. This case was dismissed on January 28, 1991 for lack of interest.
- On August 17, 1988, while the settlement of the estate was pending, petitioners filed an action for annulment of the will (Civil Case No. 88-115).
- In their complaint, petitioners claimed:
- That the properties were acquired as “civil partnership and/or conjugal properties” during Lucio’s cohabitation with Vicenta before their legal marriage in 1968.
- The properties had been acquired with funds allegedly derived from the conjugal partnership with Gliceria.
- Consolidation of proceedings occurred between Civil Case No. 88-115 and Spec. Proc. No. 4442, leading the trial court to favor the evidence of the private respondents.
Pre-Probate Disputes and Related Proceedings
- Evidence indicated that:
- The purchase money and other funds used for acquiring the disputed property were derived from the earnings of Lucio Adriano during his marriage to Gliceria.
- Lucio’s initial capital infusion of P15,000.00—used in forming a business partnership—came from the conjugal funds of his first marriage.
- Detailed documentary evidence illustrated:
- Investments made in the “Central Rice Mill & Co.” in 1947 and its subsequent amendments and re-investments increasing Lucio’s total investment over the years.
- Specific transactions, including a Deed of Sale and Mortgage (dated May 3, 1952) and other related receipts, substantiated the use of conjugal funds from his marriage to Gliceria in property acquisition.
- The evidence also showed that after a series of investments and eventual dissolution of the business partnership, Lucio became solely the owner of the rice mill, which was later registered and included in the testator’s inventory.
Evidence on the Source of Funds and Property Acquisition
- The property in dispute was evidenced by TCT No. T-56553 issued in the names of “Spouses, LUCIO ADRIANO and VICENTA VILLA.”
- The petitioners argued that:
- The certificate of title was conclusive proof of co-ownership by Vicenta.
- The Deed of Sale dated March 15, 1964, as reflected in OCT No. O-9198, designates Vicenta as a co-vendee, thus evidencing her ownership share.
- However, evidence from the trial and respondent courts established that:
- The property was acquired during Lucio’s marriage to Gliceria and is presumed conjugal unless proven otherwise.
- There was insufficient evidence to demonstrate actual joint contribution or co-ownership rights by Vicenta during the pre-marital cohabitation period.
Property Titling and Subsequent Dispute on Ownership
Issue:
- Whether the testamentary dispositions that disposed of the property, notably under TCT No. T-56553, should be upheld despite allegations of forged or mistaken co-ownership claims by Vicenta.
- Whether the will should be annulled on the ground that it disposes of property that is in fact the conjugal property of Lucio and his first wife, Gliceria.
Validity of the Testator’s Dispositions in the Last Will and Testament
- Whether the property was acquired using funds from Lucio’s conjugal partnership with Gliceria, rendering the property exclusively conjugal.
- Whether petitioners sufficiently proved that Vicenta contributed as co-owner during her period of cohabitation/pre-marriage with Lucio, in contrast to evidence showing the property was purchased with funds accruing from Lucio's first marriage.
Nature and Source of the Funds for the Acquisition of the Disputed Property
- Whether TCT No. T-56553 constitutes conclusive and indefeasible evidence of co-ownership in favor of Vicenta.
- Whether the Deed of Sale (and its notation in the OCT) best evidences Vicenta’s status as a co-vendee, even in the absence of the original document being presented in evidence.
Evidentiary Value of the Certificate of Title and the Deed of Sale
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)