Facts:

The case revolves around Pascual Antonio, a Cebu City resident who passed away on September 14, 1910, leaving a will dated December 6, 1908. In his will, he named his legitimate daughter, Laureana Antonio, as the universal heiress and bequeathed some jewelry and ₱1,000 to his wife from his fourth marriage, Claudia de los Santos, also known as Aloe. He appointed Laureana Antonio as the testamentary executrix of his estate, succeeded by Mariano Antonio if she could not serve. Laureana was duly appointed as executrix by the Court of First Instance, and after administering the estate, she filed a report on April 25, 1911, requesting a declaration of ownership over the estate’s properties.

Claudia de los Santos contested Laureana's petition, claiming entitlement to conjugal property and usufruct rights as the surviving spouse. Claimed in her opposition was a waiver of rights, which she had allegedly not consented to. However, a document surfaced where Claudia purportedly waived h

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Facts:

Background of the Deceased and His Will

• Pascual Antonio, a resident of Cebu, died on September 14, 1910.
• He executed a will on December 6, 1908, which was later probated in the Court of First Instance of Cebu.
• In his will, he:
• Instituted his legitimate daughter, Laureana Antonio, as his universal heiress.
• Devised certain items (jewelry and P1,000 in cash) to his fourth wife, Claudia de los Santos (alias Aloe).
• Designated two persons as testamentary executors:
• First, his daughter Laureana Antonio.
• Second, Mariano Antonio.

Administration of the Estate

• The court selected and approved Laureana Antonio as the executrix.
• Commissioners were appointed to assist in the estate’s administration, terminating their duties on April 25, 1911.
• On April 25, 1911, the executrix submitted her administration report and petitioned the court to declare her as the sole owner of the property left by Pascual Antonio (except for a specified hacienda in Leyte belonging to Mariano Antonio).

Opposition by the Widow, Claudia de los Santos

• On May 2, 1911, Claudia de los Santos formally appeared in the action for declaration of heirs.
• In her petition, she asserted:
• She had not waived any rights to the property left by her deceased husband.
• She did not recall executing any document that would constitute a waiver.
• The absence of an attached copy of any waiver prevented her from denying its existence under oath.
• Concurrently, evidence was presented of an instrument allegedly executed by Claudia which:
• Acknowledged knowledge of and agreement with the provisions of Pascual Antonio’s will.
• Transferred and waived her rights to the property (with the exception of jewelry and P1,000 in cash) in favor of Laureana Antonio.
• Included a clause waiving any future claims to the conjugal property or its usufruct.

The Contested Document (Waiver Instrument)

• The instrument was signed by Claudia de los Santos before a notary public (Mr. Levering) on September 20, 1910.
• The document was prepared in Spanish and interpreted twice into the Visayan dialect:
• Once by Simplicio Kodis, a clerk in Mr. Levering’s office.
• A second time by Mariano Antonio.
• Key details of the document included:
• A declaration that the entirety of Pascual Antonio’s property was his own, because it had been acquired before the marriage.
• A waiver of all rights (inclusive of any claim for conjugal property or usufruct) in favor of Laureana Antonio.
• Specific reservations for the jewelry and cash as stated in the will.
• The original document’s chain of custody:
• Initially kept by Mr. Levering.
• Later removed from a secured box by Claudia and delivered to Pacencio Rosales, who made a copy.
• The original subsequently disappeared, leading to reliance on a notary’s copy in the trial.

Testimony and Evidence Presented at Trial

• Testimony regarding the execution of the document:
• Claudia initially denied having signed any waiver document.
• Later, she admitted during trial, under oath, that she did sign the document after it was interpreted to her in the Visayan dialect.
• Evidence surrounding the document’s signing:
• The notary’s copy was admitted into evidence after explaining the chain of custody and the disappearance of the original.
• Testimony confirmed that after the interpretation, Claudia “acquiesced” and signed immediately before the notary.
• Contradictory testimony concerning the purpose of going to Mr. Levering’s office:
• Claudia initially stated that she had gone to sign an authorization for Mr. Levering to act as attorney.
• However, the court found that the document’s content plainly indicated a waiver of rights rather than the execution of any form of attorney-in-fact authorization.

Evidence on Matters of Property and Claims of Conjugal Property

• Discrepancies in the inventory and statements:
• Claudia de los Santos contended that much of the property (including houses on Magallanes Street, cattle, carabaos, and a vehicle) was acquired during her marriage and should be treated as conjugal property.
• The heiress, Laureana Antonio, provided certificates evidencing ownership of substantial stock (including cattle and carabaos) acquired prior to or outside the disputed conjugal contributions.
• Additional letters exchanged between the parties:
• Letters from Laureana referred to “our stock” and “our hacienda”—terms noted but explained as referring to some specific property without implying a share for Claudia.
• The court considered that such correspondence did not provide evidence to substantiate the widow’s claim to conjugal property.

Findings and Court’s Analytical Process

• The trial court’s findings:
• Established that Claudia de los Santos did indeed sign the document after proper interpretation.
• Rejected her claim that she had been unaware of the document’s contents.
• Noted that no proof substantiated that property acquired during the fourth marriage existed apart from what was designated in the will.
• Contentious opinions (later reversed on appeal):
• Some findings pointed to undue influence by Laureana Antonio over Claudia, emphasizing differences in character and age.
• The trial court speculated that Claudia would not have signed the instrument had she known the full extent of her rights, inferring undue influence and deceit.
• These bases for nullity later became the subject matter for appellate reversal.

Issue:

Validity of the Waiver Document

• Whether Claudia de los Santos knowingly and voluntarily executed the document waiving her rights in the conjugal property.
• Whether the document, having been interpreted twice properly, is valid and binding.

Claims to Conjugal Property and Usufruct Rights

• Whether Claudia is entitled to her statutory right to a share of the conjugal property and its usufruct as the surviving widow.
• Whether the evidence’s demonstration of the inventory and testimony regarding property acquisition supports her claim.

Allegation of Undue Influence and Deceit

• Whether Claudia was unduly influenced or deceived by Laureana Antonio into signing the waiver document.
• Whether such influence, if any, renders the document null and void under Civil Code provisions on error, violence, or deceit.

Procedural and Evidentiary Concerns

• Whether the trial court’s findings outside of the pleadings and proofs were proper.
• Whether the reliance on witness testimony and the chain of custody of the document creates sufficient basis for any ruling on the waiver’s nullity.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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