Case Digest (G.R. No. 253426) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves a petition for review on certiorari filed by Ana Maria C. Manguerra (petitioner) challenging the Decision and Resolution of the Court of Appeals (CA) dated June 17, 2019, and September 8, 2020, respectively. The dispute arose from the probate and distribution of the estate of the late Concepcion A. Cuenco Vda. De Manguerra (decedent). The petitioner filed the Petition for Probate of the decedent’s Last Will and Testament on January 27, 2003, praying for the allowance of the will and her appointment as the executor. The will disinherited all but one of the decedent’s grandchildren (respondents) except Gregorio Constantino E. Manguerra, who was named to receive a specific bequest. The Regional Trial Court (RTC) of Makati City allowed the will but invalidated the disinheritance clause and ordered the issuance of letters testamentary to the petitioner.
Subsequently, after several years of litigation, the RTC issued a Partial Distribution Order in 2013, distributi
...
Case Digest (G.R. No. 253426) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Case
- Ana Maria C. Manguerra (petitioner) filed a Petition for the probate of the Last Will and Testament of Concepcion A. Cuenco Vda. De Manguerra (decedent) before the RTC of Makati City on January 27, 2003.
- The will named petitioner as executor and disinherited all but one grandchild (Gregorio) of the decedent’s late son from the estate.
- The will specified detailed distributions of estate properties and shares among various heirs and legatees, including petitioner, Gregorio, and other grandchildren.
- Proceedings in RTC
- On April 15, 2003, the RTC allowed the decedent’s will, appointed petitioner as executrix, but invalidated the disinheritance provision in the will as premature to rule on its validity.
- Petitioner filed a Motion for Partial Reconsideration, which was granted; the issue of disinheritance was deferred for further proceedings.
- A Motion for the distribution of estate properties was filed by petitioner on February 15, 2005.
- The RTC issued a Partial Distribution Order on October 21, 2013, directing distribution of certain estate properties and shareholdings. This included a directive for Gregorio to accept or reject his bequest.
- Respondents (other heirs) filed a Motion for Reconsideration against the Partial Distribution Order, which was denied on February 13, 2014.
- Respondents filed their Notice of Appeal and Record on Appeal on April 2, 2014, challenging the Partial Distribution Order. The RTC approved the appeal records on June 2, 2014.
- While the appeal was pending, petitioner filed a Motion for Final Distribution of the remainder of the estate on July 28, 2014, not opposed by respondents.
- On September 17, 2014, the RTC issued a Final Distribution Order, completing distribution of all remaining estate assets and ordering that Gregorio's unaccepted property revert to the estate and be distributed to petitioner.
- Respondents filed a Motion to Inhibit on September 30, 2014, which was granted, and subsequently filed a Motion for Reconsideration on October 10, 2014, which was denied on September 7, 2015.
- Respondents received the denial order on September 22, 2015, and filed a Notice of Appeal with Record on Appeal on October 21, 2015 (29 days after receipt), challenging the Final Distribution Order.
- RTC’s Disapproval and Petitions
- On April 5, 2017, the RTC disapproved respondents’ record on appeal for being filed out of time, stating the proper remedy after final disposition was a regular appeal with a 15-day period for filing notice, not a record on appeal.
- Respondents’ motion for reconsideration was denied on June 16, 2017; the RTC also issued an Entry of Judgment for the Final Distribution Order and prior order dated September 7, 2015.
- Respondents filed a Petition for Certiorari before the Court of Appeals (CA) alleging grave abuse of discretion by the RTC in disapproving their appeal filing and the issuance of the Entry of Judgment.
- On June 17, 2019, the CA granted the Petition for Certiorari, annulled and set aside the RTC’s Orders disapproving the appeal documents, and ordered RTC to approve the notice and record on appeal filed by respondents.
- Petitioner’s motion for reconsideration before the CA was denied on September 8, 2020.
- Petition before the Supreme Court
- Petitioner filed the instant Petition for Review on Certiorari contesting the CA’s ruling that in special proceedings disposing of the entire case, appeal must still be by notice and record on appeal, not ordinary appeal within 15 days.
- Respondents opposed, urging affirmance of the CA ruling.
Issues:
- Whether a record on appeal is required in special proceedings where the trial court has already completely disposed of the case.
- Whether the proper mode of appeal in such special proceedings is by ordinary appeal (notice only) within 15 days or by filing both notice and record on appeal within 30 days as required under Rule 41, Sections 2(a) and 3 of the Rules of Court.
- Whether the RTC gravely abused its discretion in disapproving respondents’ notice of appeal and record on appeal as filed out of time in challenging the Final Distribution Order.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)