Facts:

The case involves a Petition for Review on Certiorari filed by Ana Maria C. Manguerra (petitioner) against Ma. Patricia Concepcion E. Manguerra-Aberasturi and several members of the Manguerra family (respondents). The records show that petitioner filed a Petition for the probate of the Last Will and Testament of the decedent, Concepcion A. Cuenco Vda. De Manguerra, on January 27, 2003, in the Regional Trial Court (RTC) of Makati City, which was documented as SP Proc. No. M-5599. Petitioner sought both the allowance of the decedent's will and her appointment as the executor of the estate. In this executed will, the decedent designated petitioner as the executor and disinherited all but one of her grandchildren—Gregorio Constantino E. Manguerra—from any share of her estate. In her will, the decedent specifically laid out the bequests to various beneficiaries, including properties and cash allocations.

On April 15, 2003, the RTC approved the will but invalidated the disinherit

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Facts:

Initiation of Probate and Will Provisions

• In January 2003, Ana Maria C. Manguerra, the petitioner, filed a petition for the probate of the Last Will and Testament of decedent Concepcion A. Cuenco Vda. De Manguerra before the RTC of Makati City under SP Proc. No. M-5599.
• The will explicitly appointed petitioner as the executor and set forth detailed bequests, including:

- Specific real properties and lots (e.g., agricultural lot in Toledo, residential lot in Cebu City) designated to different beneficiaries. - A disinheritance clause affecting all grandchildren of Mariano Jesus Manguerra, Jr. except Gregorio Constantino E. Manguerra. - The distribution of the decedent’s estate among various beneficiaries. - Specific directions on monetary bequests, real property transfers, and the allocation of shareholdings in corporations.

Initial RTC Orders and Subsequent Motions

• On April 15, 2003, the RTC allowed the will, issued letters testamentary to the petitioner, and invalidated the disinheritance provision on the ground that the statutory basis for disinheritance was not met.
• Petitioner subsequently filed a motion for partial reconsideration, which the RTC granted on July 16, 2003, declaring that the issue of disinheritance was premature for determination at that stage.
• On February 15, 2005, petitioner further moved for the distribution of the estate properties per the provisions of the will.
• The RTC, by its Resolution (Partial Distribution Order) dated October 21, 2013, directed:

- Partial distribution of the decedent’s estate, specifically detailing the lots and shareholdings bequeathed to petitioner and certain other beneficiaries. - Submission by Gregorio of his manifestation of acceptance or rejection of his bequeathed properties, as his acceptance was pending.

Respondents’ Appeals and RTC’s Later Orders

• Dissatisfied with the Partial Distribution Order, the respondents (comprising Ma. Patricia Concepcion E. Manguerra-Aberasturi, Jose Mariano E. Manguerra, Christine Martina E. Manguerra, Mamerto Luis E. Manguerra, Juan Paolo E. Manguerra, and Gregorio Constantino E. Manguerra) filed:

- A Motion for Reconsideration which was denied by the RTC. - A Notice of Appeal and a Record on Appeal, both initially filed on April 2, 2014. - This order granted petitioner’s motion and finalized the distribution of the remaining estate assets in accordance with the will. - It also provided that the property designated to Gregorio, upon his failure to submit the required acceptance, be reverted and redistributed in favor of the petitioner. - They filed a Motion to Inhibit on September 30, 2014, which the RTC granted. - After additional proceedings and a Motion for Reconsideration (denied on September 7, 2015), respondents filed another Notice of Appeal with an attached Record on Appeal on October 21, 2015, challenging the Final Distribution Order. - In special proceedings, where multiple appeals are allowed, the proper mode of appeal is by filing both a notice of appeal and a record on appeal within 30 days, not 15. - The respondents had timely satisfied the reglementary period under Section 2(a) and Section 3 of Rule 41 of the Rules of Court.

Additional Contentions and Concurrences

• Petitioner contended that once the RTC had fully disposed of the case by issuing the Final Distribution Order, no record on appeal was necessary as no pending matter remained for adjudication by the trial court.
• The respondents, as well as several concurring opinions, maintained that:

- The Rules of Court clearly require a record on appeal in special proceedings. - Precedents such as Aranas, Spouses Lebin, and Brual necessitate strict compliance with the appellate framework provided under Rule 41.

Issue:

Procedural Issue on the Mode and Timing of Appeal

• Whether a record on appeal is mandatory in special proceedings even when the trial court appears to have fully disposed of the case.
• Whether the reglementary period for filing an appeal in such cases remains 30 days as prescribed by Section 3, Rule 41, or is shortened to 15 days when no further issues remain for adjudication by the RTC.

Substantive Issue on the Court’s Authority

• Whether the RTC erred in disapproving the respondents’ appeal (notice of appeal and record on appeal) on the ground that the case was “fully disposed of.”
• The broader implications of strictly enforcing the procedural requirements in light of the multi-part character of special proceedings (such as probate and estate distribution).

Interpretative Issue of the Rules of Court

• Whether precedents like Republic v. Nishina, which suggested that a record on appeal may not be necessary when no additional matters remain for the lower court’s determination, are applicable to cases involving the probate and distribution of an estate.
• How to harmonize the requirements of Section 2(a) and Section 3 of Rule 41 with the pertinent facts of a case that involves multiple appeals across different stages of estate proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)