Case Digest (G.R. No. 205451)
Facts:
The case involves Elizabeth Brual as the petitioner and Jorge Brual Contreras, Lourdes Brual-Nazario, Erlinda Brual-Binay, Rodolfo Brual, Renato Brual, Violeta Brual, David De Jesus, and Antonio De Jesus as the respondents. The events leading to this case began when Fausta Brual, who remained single throughout her life, passed away. She was under the care of her nephew, Ireneo Brual, and his wife, Elizabeth Brual. On July 22, 2009, Elizabeth, as an instituted heir and co-executor, filed a petition for the probate of Fausta's last will and testament before the Regional Trial Court (RTC) of Manila. The respondents, who are Fausta's nephews and nieces, contested the validity of the will, claiming that Elizabeth, being a niece by affinity and a de facto guardian, should not have been named as an heir or executor. They also argued that the probate petition was defective as it did not include the names, ages, and addresses of Fausta's blood relatives.
The RTC initial...
Case Digest (G.R. No. 205451)
Facts:
Background of the Case
- Fausta Brual, who remained single throughout her life, was cared for by her nephew Ireneo Brual and his wife, Elizabeth Brual (petitioner).
- On July 22, 2009, Elizabeth, as an instituted heir and co-executor, filed a petition for the probate of Fausta’s last will and testament before the Regional Trial Court (RTC) of Manila.
Respondents' Motion for Intervention
- Jorge Brual Contreras, Lourdes Brual-Nazario, Erlinda Brual-Binay, Rodolfo Brual, Renato Brual, Violeta Brual, David De Jesus, and Antonio De Jesus (respondents), who are Fausta’s nephews and nieces, filed a motion for intervention.
- They alleged that Fausta’s will, which left all her properties to Elizabeth and her husband, was dubious. They argued that Elizabeth, being a niece by affinity and a de facto guardian, should not have been named heir or executor.
- They also claimed that the petition for probate was defective because it did not include the names, ages, and addresses of Fausta’s blood relatives.
RTC’s Denial of the Motion for Intervention
- On November 4, 2010, the RTC denied the respondents’ motion for intervention, ruling that Fausta, who died without compulsory heirs, could dispose of her estate as she wished under Article 842 of the Civil Code.
- The RTC also held that the respondents were not entitled to notice of the probate proceedings, and even if they were, the defect was cured by the publication of the notice.
Respondents' Appeal and Procedural Missteps
- The respondents filed a motion for reconsideration, which was denied on January 14, 2011.
- On February 3, 2011, they filed a notice of appeal but failed to file a record on appeal as required by Sections 2 and 3 of Rule 41 of the Rules of Court.
- The RTC dismissed their appeal on April 27, 2011, citing their failure to file a record on appeal.
- The respondents filed an omnibus motion for reconsideration and to admit their record on appeal, which the RTC denied on July 27, 2011.
Court of Appeals’ Ruling
- The respondents filed a petition for certiorari before the Court of Appeals (CA), which reversed the RTC’s dismissal of their appeal.
- The CA held that the appeal should not be dismissed based on procedural technicalities and that the respondents’ failure to file a record on appeal was due to an honest belief that it could be filed after the notice of appeal.
Issue:
- Whether the Court of Appeals erred in reversing the RTC’s dismissal of the respondents’ appeal despite their failure to comply with the mandatory rules on appeals.
- Whether the Court of Appeals erred in giving due course to the respondents’ petition despite the appeal not being perfected and having lapsed in finality.
- Whether the Court of Appeals erred in allowing the respondents’ petition despite it being the wrong mode of appeal.
Ruling:
The Supreme Court granted the petition and reversed the Court of Appeals’ decision. The RTC’s dismissal of the respondents’ appeal was reinstated.
Ratio:
Right to Appeal is Statutory and Must Comply with Rules
- The right to appeal is not a natural right but a statutory privilege that must be exercised in accordance with the law. Failure to comply with the rules on appeals, such as filing a record on appeal in special proceedings, renders the judgment final and executory.
Requirement of Record on Appeal in Special Proceedings
- In special proceedings, both a notice of appeal and a record on appeal must be filed within 30 days from notice of the judgment or final order. The respondents failed to file the record on appeal within the prescribed period, which is mandatory and jurisdictional.
No Excusable Negligence
- The respondents’ failure to file the record on appeal was not due to excusable negligence. Their claim of an honest belief that the record on appeal could be filed later was insufficient to justify their non-compliance with the rules.
Strict Compliance with Procedural Rules
- The Supreme Court emphasized that procedural rules must be strictly followed to ensure the orderly administration of justice. Exceptions to these rules are limited and cannot be applied based on mere inadvertence or honest belief.
Finality of Judgment
- Since the respondents failed to perfect their appeal within the prescribed period, the RTC’s denial of their motion for intervention became final and immutable.
Conclusion:
The Supreme Court ruled that the Court of Appeals erred in reversing the RTC’s dismissal of the respondents’ appeal. The RTC’s orders dismissing the appeal and denying the omnibus motion for reconsideration were reinstated.