Case Digest (G.R. No. 156407) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Thelma M. Aranas v. Teresita V. Mercado et al., G.R. No. 156407, decided January 15, 2014 under the 1987 Constitution, petitioner Thelma Aranas and respondent Franklin Mercado are children of the late Emigdio S. Mercado by his first marriage; respondents Teresita Mercado (second wife) and her five children are Emigdio’s surviving spouse and heirs. Emigdio died intestate on January 12, 1991, owning corporate shares in Mervir Realty Corporation and Cebu Emerson Transportation Corporation, and several real properties, including Lot No. 3353 in Badian, Cebu, and parcels transferred by deeds of assignment shortly before his death. On June 3, 1991 Thelma filed a petition with the Regional Trial Court (RTC) of Cebu for appointment of Teresita as administrator. After letters issued in September 1992, Teresita submitted an inventory in December listing only personalty and corporate stocks, omitting real properties. Thelma moved to compel amendment and testimony. After hearings from 19 Case Digest (G.R. No. 156407) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Decedent
- Emigdio S. Mercado died intestate on January 12, 1991, survived by his second wife Teresita V. Mercado and seven children (five from second marriage, two from first marriage: Thelma M. Aranas and Franklin L. Mercado).
- Emigdio owned various real properties and corporate shares in Mervir Realty Corporation and Cebu Emerson Transportation Corporation; he sold or assigned properties to Mervir Realty prior to death.
- Probate Proceedings
- On June 3, 1991, petitioner Thelma filed in the RTC of Cebu a petition to appoint Teresita as administrator of Emigdio’s estate; letters of administration were issued on September 7, 1992.
- On December 14, 1992, Teresita submitted an inventory listing only personal properties (cash, furniture, jewelry) and corporate shares, excluding real properties allegedly sold or assigned.
- Inventory Dispute and RTC Hearings
- Thelma moved to amend the inventory and examine the administrator; RTC ordered compliance on January 8, 1993.
- Teresita submitted supporting documents on January 21, 1993; Thelma persisted in opposing approval and sought examination under oath.
- Parties agreed to submit the inclusion/exclusion issue to the RTC; hearings spanned nearly eight years.
- RTC Orders
- On March 14, 2001, the RTC denied approval of the inventory, ordered Teresita to re-do the inventory including five categories of omitted properties (inheritance shares, conjugal assets, bank account funds, Lot 3353, and properties assigned two days before death) and to render an accounting within 60 days.
- On May 18, 2001, the RTC denied reconsideration, ruling that the heirs’ prior consent estopped them from challenging its jurisdiction.
- Court of Appeals Decision
- Teresita and co-respondents filed a petition for certiorari in the CA, claiming grave abuse of discretion by the RTC.
- On May 15, 2002, the CA granted relief in part: it reversed the RTC orders only as to Lot 3353 and the assigned parcels, affirmed the rest.
- The CA denied motion for reconsideration on November 15, 2002.
- Supreme Court Review
- The Supreme Court granted Teresita’s petition for review on certiorari.
- The Court resolved procedural and substantive issues regarding the RTC’s interlocutory orders and its exercise of probate jurisdiction.
Issues:
- Whether certiorari under Rule 65 was the proper remedy to assail the RTC’s interlocutory orders on inventory approval.
- Whether the RTC gravely abused its discretion in ordering inclusion of properties transferred or registered in the name of third parties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)