Facts:

The case centers on Amelia P. Arellano, represented by her daughters Agnes P. Arellano and Nona P. Arellano, as the petitioner against respondents Francisco Pascual and Miguel N. Pascual. The key events began with the death of Angel N. Pascual Jr. intestate on January 2, 1999, leaving his siblings, including petitioner and respondents, as his heirs. On April 28, 2000, the respondents filed a petition for "Judicial Settlement of Intestate Estate and Issuance of Letters of Administration" at the Regional Trial Court (RTC) of Makati, asserting that a parcel of land, which Angel had donated to Amelia, should be considered an advance legitime to her. Respondent's nephew, Victor, was appointed as Administrator of the estate by the RTC. The trial court, while acting as a probate court, held that it could not determine the validity of the donation but considered the deed valid since it was notarized. By relying on Article 1061 of the New Civil Code, the court deemed that t

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Facts:

Decedent and Heirs

• Angel N. Pascual Jr., who died intestate on January 2, 1999, is the decedent.
• His heirs include his siblings:
• Petitioner Amelia P. Arellano, represented by her daughters Agnes P. Arellano and Nona P. Arellano.
• Respondents Francisco Pascual and Miguel N. Pascual.

Litigation Background and Proceedings at the Trial Level

• Respondents filed a petition for the Judicial Settlement of the Intestate Estate and Issuance of Letters of Administration (Special Proceeding Case No. M-5034) on April 28, 2000, before the Regional Trial Court (RTC) of Makati.
• The dispute centered on a parcel of land located in Teresa Village, Makati, transferred to petitioner by way of a Deed of Donation, which respondents argued should be considered an advance legitime.
• Victor, the nephew of the respondents, was provisionally appointed as Administrator of the estate by Branch 135 of the Makati RTC.

Court Findings on the Donated Property

• The property in question, now under petitioner’s name by Transfer Certificate of Title (TCT) No. 181889, was challenged by the respondents.
• Although the trial court (acting as a probate court) stated it was precluded from determining the validity of the donation, it provisionally found:
• The Deed of Donation to be valid based on the presumption of notarized documents.
• That the donated property should be subject to collation pursuant to Article 1061 of the New Civil Code, which mandates the inclusion of donations or gratuitous dispositions received during the decedent’s lifetime in the computation of the legitime.

Partition of the Estate by the Probate Court

• The probate court partitioned various properties from the intestate estate, including:
• The property covered by TCT No. 181889.
• Rental receivables, shares in stocks of San Miguel Corporation and Paper Industries Corp., and other properties such as a house and lot, a vacant lot, agricultural land, and interests in a mining company.
• The partition order allocated:
• The donated property to petitioner Amelia P. Arellano.
• The remaining properties, including specific real properties and rental incomes, to respondents Francisco and Miguel Pascual, subject to equalization measures by appraisal for donation-related values.
• A residual equal division among petitioner and respondents.

Appellate Proceedings and Issues Raised

• On appeal, petitioner challenged several aspects of the trial court’s ruling:
• The inclusion of the donated property as part of the decedent’s estate at the time of his death.
• The application of collation on the donated property under Article 1061.
• The entitlement of respondents as compulsory heirs entitled to legitimes.
• The unequal partition of the estate among the legal or intestate heirs.
• The Court of Appeals (CA) partly sustained the trial court’s ruling by maintaining that:
• The property was subject to collation, as it amounted to a donation inter vivos affecting the equality rule in intestate succession.
• However, CA noted that petitioner had submitted prima facie evidence that certain shares of stocks belonging to the decedent were omitted from the estate’s inventory.

Supreme Court Review and Considerations

• Petitioner raised errors with the appellate ruling, particularly contesting:
• The determination that the donated property was part of the decedent’s estate and subject to collation.
• The classification of respondents as compulsory heirs and the method of partition.
• The Supreme Court analyzed:
• The doctrine and purpose of collation, emphasizing its dual facets: a mathematical addition in computing the estate and the return of property disposed of during the decedent’s lifetime.
• The absence of compulsory heirs, noting that the decedent was survived solely by collateral relatives, who do not claim legitime protection under the law.
• The Supreme Court ultimately granted petitioner’s petition and remanded the case to the RTC for further proceedings regarding the final determination of the estate’s composition and its equal distribution among the heirs.

Issue:

• Whether the property donated by Angel N. Pascual Jr. to petitioner Amelia P. Arellano should be considered as part of the decedent’s estate at the time of his death.
• Whether the donated property is subject to collation under Article 1061 of the New Civil Code.
• Whether the respondents, as surviving siblings (collateral relatives), qualify as compulsory heirs entitled to legitimes.
• Whether the estate, after determining inclusion or exclusion of the donated property, should have been partitioned equally among the heirs in accordance with applicable provisions of the Civil Code.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)