Adm. Matter No. 384 - People vs. Jaurigue

Fausta Brual died single and without compulsory heirs; she was cared for by her nephew Ireneo Brual and his wife, Elizabeth Brual (petitioner).
On July 22, 2009, Elizabeth, as instituted heir and co-executor, filed a petition for probate of Fausta’s last will and testament before the RTC of Manila.

Respondents (nephews and nieces) moved to intervene, alleging the will’s disposition in favor of Elizabeth and her husband was dubious and the petition defective for omitting names/addresses of blood relatives.
The RTC denied intervention (Order, Nov 4, 2010) and denied reconsideration (Order, Jan 14, 2011), holding Fausta could dispose of her entire estate and any formal defect was cured by publication.
Respondents filed a notice of appeal on February 3, 2011 but did not file the required record on appeal.
The RTC dismissed the appeal for failure to file the record (Order, Apr 27, 2011) and denied an omnibus motion to admit the record on appeal (Resolution, July 27, 2011).
Respondents petitioned the Court of Appeals (CA) for certiorari; the CA reversed and set aside the RTC orders (Decision, July 2, 2012; Resolution denying reconsideration, Jan 16, 2013).

Whether the CA erred in reversing the probate court’s dismissal of respondents’ appeal and applying a liberal interpretation to mandatory appeal procedures despite respondents’ non-compliance.
Whether the CA erred in giving due course to respondents’ petition when the appeal was not perfected and had become final.
Whether the CA erred in permitting the wrong mode of appeal.