Case Digest (G.R. No. 187843)
Facts:
The case involves Capitol Sawmill Corporation and Columbia Wood Industries Corporation as petitioners, and Concepcion Chua Gaw, Angelo Chua Gaw, John Barry Chua Gaw, Leonard Brandon Chua Gaw, and Julita C. Chua as respondents. The events leading to this case began with the death of Chua Chin on June 19, 1986, followed by the death of Chan Chi on October 16, 1993. They were the founders of the two corporations in question and had seven children, including Concepcion and Julita. On June 2, 1995, Concepcion and her husband, Antonio Gaw, filed a complaint for Determination of Shares in and Partition of the Estate of their deceased parents against their siblings and the two corporations in the Regional Trial Court (RTC) of Valenzuela. The respondents claimed that the assets of the corporations were wholly owned by their deceased parents and should be included in the estate for partition among the heirs. The petitioners, in their answer, contended that the complaint did not state a...
Case Digest (G.R. No. 187843)
Facts:
- Founders and Heirs: Spouses Chua Chin and Chan Chi founded Capitol Sawmill Corporation and Columbia Wood Industries Corporation. They had seven children, including Concepcion Chua Gaw and Julita Chua. Chua Chin died on 19 June 1986, and Chan Chi died on 16 October 1993.
- Legal Action: On 2 June 1995, Concepcion Chua Gaw and her husband, Antonio Gaw, filed a complaint for Determination of Shares in and Partition of the Estate of their deceased parents against their siblings and the two corporations. They claimed that the deceased parents wholly owned the assets and investments in the corporations, which should form part of their estate for partition among the heirs.
- Defendants' Response: The corporations, as defendants, countered that the complaint lacked a cause of action against them.
- Substitution of Parties: After Antonio Gaw's death on 10 December 1998, his children (Angelo, John Barry, and Leonard Brandon Chua Gaw) were substituted as plaintiffs. Julita Chua was later allowed to join Concepcion as a co-plaintiff.
- Trial Proceedings: During the trial, Concepcion and Julita testified, and plaintiffs submitted documentary evidence. Petitioners filed a Demurrer to Evidence, arguing that the properties of the corporations could not be included in the estate of the deceased, citing the case of Lim v. Court of Appeals.
- Trial Court's Ruling: On 3 September 2007, the trial court denied the Demurrer to Evidence, distinguishing the Lim case and noting that the Chua Suy Phen case had already validated the plaintiffs' causes of action.
- Appeal to the Court of Appeals: Petitioners filed a special civil action for certiorari, but the Court of Appeals dismissed the petition on 11 May 2009, affirming the trial court's decision.
Issue:
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Ruling:
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Ratio:
- Cause of Action: A cause of action exists if the allegations in the complaint, taken as true, entitle the plaintiff to relief. The plaintiffs' complaint sufficiently alleged their right to inherit and share in the ownership of the corporations.
- Distinction from Lim Case: The Lim case involved specific real properties registered under corporations, while this case involves the totality of investments made by the deceased parents in the corporations.
- Jurisdiction and Validity of Claims: The trial court has jurisdiction to determine the heirs' rights to inherit and share in the ownership of the corporations, as affirmed in Chua Suy Phen.
- Procedural Obliquity: The Court emphasized that petitioners' attempts to stall the proceedings through procedural maneuvers must be stopped, and the case should be resolved expeditiously.