Case Digest (G.R. No. 139868) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 139868, decided on June 8, 2006, Alonzo Q. Ancheta (petitioner) served as ancillary administrator of the Philippine estate of Audrey O’Neill Guersey, an American citizen domiciled in Maryland, whose will bequeathed her entire estate—including a Makati real property, a Citibank account, and A/G Interiors, Inc. shares—to her husband W. Richard Guersey and appointed him executor. Audrey’s will was probated in Baltimore and admitted for probate in the Court of First Instance of Rizal, Branch 25 (Special Proceeding No. 9625) in 1982. Petitioner filed Audrey’s inventory and appraisal. In 1984, Richard died, leaving a will that bequeathed his entire estate to his second wife, Candelaria Guersey‐Dalaygon (respondent), save the A/G Interiors shares for his adopted daughter, Kyle Guersey Hill. His will was probated in Maryland and submitted before the Regional Trial Court of Makati (Special Proceeding No. M-888). As Audrey’s ancillary administrator, petitioner in October 1987 Case Digest (G.R. No. 139868) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and initial probate
- Spouses Audrey O’Neill (Audrey) and W. Richard Guersey (Richard), American citizens domiciled in Maryland, U.S.A., residing in the Philippines for 30 years, had an adopted daughter, Kyle Guersey Hill (Kyle).
- On July 29, 1979, Audrey died leaving a will that bequeathed her entire estate to Richard and designated him executor. The Orphan’s Court of Baltimore admitted the will and appointed James N. Phillips executor; Atty. Alonzo Q. Ancheta was named ancillary administrator in the Philippines.
- Philippine probate of Audrey’s estate
- October 12, 1982: The Court of First Instance of Rizal (Pasig), Special Proceeding No. 9625, admitted Audrey’s will. As ancillary administrator, petitioner filed an inventory and appraisal of:
- Audrey’s conjugal share in real estate at 28 Pili Avenue, Forbes Park, Makati, valued at ₱764,865.00.
- A Citibank current account balance of ₱12,417.97.
- Sixty-four thousand four hundred forty-four shares of A/G Interiors, Inc., worth ₱64,444.00.
- Death of Richard and Philippine probate of his estate
- July 20, 1984: Richard died, leaving a will bequeathing his entire estate to respondent Candelaria Guersey-Dalaygon (respondent), except the A/G Interiors shares left to Kyle. The Orphan’s Court of Ann Arundel, Maryland, admitted the will; James N. Phillips was executor and designated Atty. William Quasha ancillary administrator in the Philippines (SP No. M-888).
- July 24, 1986: Atty. Quasha appointed ancillary administrator by the Regional Trial Court of Makati, Branch 138.
- Partition and initial distribution orders
- October 1987: In SP No. 9625, petitioner moved to declare Richard and Kyle as Audrey’s heirs and filed a project of partition allocating:
- A34 undivided interest in the Makati property, 48.333 A/G Interiors shares, and ₱9,313.48 to Richard.
- A14 undivided interest in the Makati property, 16.111 A/G Interiors shares, and ₱3,104.49 to Kyle.
- February 12 and April 7, 1988: The trial court approved the partition and directed issuance of a new title (TCT No. 155823) in the names of the Estate of W. Richard Guersey (A34 interest) and Kyle (A14 interest), transfer of shares, and release of bank funds to the ancillary administrator.
- Subsequent partition of Richard’s estate and respondent’s opposition
- 1991: In SP No. M-888, a project of partition allocated 2/5 of Richard’s A34 interest in the Makati property to respondent and 3/5 to Richard’s children. Respondent opposed, invoking Maryland law that a legacy passes the testator’s entire interest.
- December 6, 1991: The trial court disapproved the project and adjudicated the entire A34 interest in the Makati property to respondent.
- Annulment proceedings in the Court of Appeals
- October 20, 1993: Respondent filed an amended complaint in the CA for annulment of the SP No. 9625 orders, alleging petitioner’s breach of fiduciary duty, extrinsic fraud, and disregard of Maryland succession law.
- March 18, 1999: The CA annulled the February 12 and April 7, 1988 orders and ordered:
- Adjudication of Audrey’s entire estate in favor of the Estate of W. Richard Guersey.
- Cancellation of TCT No. 155823 and issuance of a new title in the Estate of W. Richard Guersey.
- August 27, 1999: The CA denied petitioner’s motion for reconsideration.
Issues:
- Are the SP No. 9625 orders of February 12 and April 7, 1988 valid, final, and beyond annullment?
- Did the petitioner’s failure to introduce and apply Maryland law and disregard Audrey’s will constitute extrinsic fraud and breach of fiduciary duty warranting annulment of those orders?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)