G.R. No. 154182 - Teves vs. Sandiganbayan

Adoracion C. Campos, a U.S. citizen and permanent resident of Philadelphia, died on January 31, 1977 in Manila, Philippines.
She was survived by her father, Hermogenes Campos (only compulsory heir), and three sisters: Nenita C. Paguia, Remedios C. Lopez, and Marieta C. Medina.

Hermogenes executed an Affidavit of Adjudication (Rule 74, Sec. 1, Rules of Court) claiming the entire estate.
On November 25, 1977, Nenita filed a petition to probate a July 10, 1975 will executed in Pennsylvania and to be appointed administratrix of the Philippine estate.
On January 11, 1978, Hermogenes opposed, alleging forgery, null intrinsic provisions, and inapplicability of U.S. law.
On December 1, 1978, Hermogenes filed a “Motion to Dismiss Opposition (With Waiver of Rights or Interests)” confirming the will’s authenticity, leading to an ex parte presentation of evidence.
On January 10, 1979, Judge Leonidas admitted the will to probate in the Philippines and appointed Nenita administratrix upon posting a ₱5,000 bond.
On May 25, 1979, Hermogenes filed a petition for relief to set aside the January 10 order, alleging fraud in his withdrawal of opposition. He failed to present evidence at hearings and his petition was dismissed on June 19, 1980; his motion to vacate was likewise denied.
Hermogenes died on June 6, 1982; Polly Cayetano was substituted as petitioner in this certiorari proceeding, alleging jurisdictional defects, denial of due process, and improper divestment of legitime.

Whether the respondent judge abused discretion in permitting withdrawal of opposition and conducting an ex parte probate.
Whether a compulsory heir may validly waive or renounce inheritance rights by motion rather than by authenticated petition or instrument.
Whether a forced heir’s legitime can be divested by admitting to probate a will that makes no provision for him.
Whether the dismissal of the petition for relief without specific notice or hearing violated due process.
Whether the Manila Court of First Instance lacked jurisdiction over the probate of a foreign decedent’s estate.