Title
Araujo vs. Celis
Case
G.R. No. 2308
Decision Date
Aug 3, 1910
Rosario’s will, authenticated by an unauthorized gobernadorcillo near Pototan, was ruled invalid; her heirs, not her husband’s estate, inherited the hacienda Pangpang.
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Case Digest (G.R. No. 2308)

Facts:

Inheritance and Property Ownership

  • Rosario Darwin Araujo inherited the hacienda known as Pangpang and other properties from her mother, Asuncion Araujo y Belen.
  • Rosario married Jose Araujo y Celis, the son of the defendant, Gregoria Celis.
  • Rosario died on January 22, 1888, without descendants or ascendants, leaving only collateral relatives, including the plaintiffs, Nieves Araujo et al., who claimed to be her nearest heirs.

Dispute Over the Will

  • The plaintiffs sought to inherit Rosario’s estate, arguing that the property should be delivered to them as her heirs.
  • The defendant, Gregoria Celis, admitted that the property belonged exclusively to Rosario but claimed that Rosario had executed a valid will bequeathing all her property to her husband, Jose Araujo.
  • Jose Araujo died in 1889 without a will, and the defendant, as his heir, claimed ownership of the property.

Execution of the Will

  • The defendant alleged that Rosario executed a will before her death, signed by eight witnesses, including Nieves Araujo, Rosario’s tutoress.
  • The will was executed before Juan Celis, the gobernadorcillo of Barotac Nuevo, as Rosario was too weak to sign due to illness.
  • The will was sent to the Court of First Instance and registered without calling the witnesses to testify.

Distance Between Towns

  • The distance between Barotac Nuevo (where the will was executed) and Pototan (the seat of the judicial district and location of the notary) was 9,515 meters, which is less than 2 leagues (11,144 meters).

Issue:

  1. Validity of the Will: Whether Rosario Darwin executed a valid will before her death, as claimed by the defendant.
  2. Authority of the Gobernadorcillo: Whether the gobernadorcillo of Barotac Nuevo had the legal authority to authenticate the will, given the distance between Barotac Nuevo and Pototan.
  3. Ownership of the Property: Whether the defendant, Gregoria Celis, lawfully acquired the property through the will of Rosario Darwin.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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