G.R. No. 10033 - City of Manila vs. Roman Catholic Archbishop of Manila

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G.R. No. 10033: City of Manila vs. Roman Catholic Archbishop of Manila

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Title Source: Supreme Court: City of Manila vs. Roman Catholic Archbishop of Manila

Case: G.R. No. 10033

Decision Date: Aug 30, 1917

Ana Sarmiento's 1668 will established a chaplaincy, designating the Roman Catholic Archbishop of Manila as perpetual administrator. The City of Manila's 1913 escheat claim was denied, as the will validly designated heirs and administrators, precluding escheat under Act No. 190.

Case Digest (G.R. No. 10033)
Expanded Legal Reasoning Model

Facts:

Initiation of the Case

The action was commenced on February 15, 1913, in the Court of First Instance of the City of Manila.
The purpose of the petition was to have declared escheated to the City of Manila certain property located in and around the city.
The property in question comprised five parcels of land situated in the districts of Malate and Paco, as identified in a plan (Office of the Department of Engineering and Public Works, City of Manila, Plan No. B-10-27).

Plaintiff’s Theory

The plaintiff asserted that Ana Sarmiento was the owner of the property.
It was alleged that Ana Sarmiento had died in 1668 without leaving "any heir or person entitled to the same," which would satisfy the condition for escheatment.

Testimony and Documentary Evidence

Evidence established that Ana Sarmiento resided in Manila with her husband prior to November 17, 1668.
On November 17, 1668, Ana Sarmiento executed her will, and on November 23, 1668, she appended a codicil to that same will.
Further evidence showed that on May 19, 1669, she made another will which incorporated, at least in part, the provisions of the earlier codicil.
Her will contained specific provisions:

The establishment of a “Capellania de Misas.”
The appointment of her nephew, Pedro del Castillo, as the first chaplain of the aforementioned capellania.
Directions for the subsequent perpetual administration of the property succeeding the initial appointment.

It was established that Ana Sarmiento died around the year 1672.

Administration of the Property

For over two centuries, the Roman Catholic Archbishop of Manila, through various agencies, had been administering the property in accordance with the terms set forth in Ana Sarmiento’s will.
The administration was maintained by the rightful successor, as clearly provided by the testamentary instructions of Ana Sarmiento, ensuring the property was managed for the benefit of the intended beneficiary.

Relevant Statutory Provision

Section 750 of Act No. 190 states that property may be declared escheated when a person dies intestate, leaving no heir or person by law entitled to the same.
The statute, together with sections 751 and 752, provides the procedural basis for declaring property escheated.

Issues:

Whether the property in question can be declared escheated under Section 750 of Act No. 190.

The central issue is if the property of Ana Sarmiento falls within the parameters for escheatment, given that she allegedly died without an heir.
Whether the existence of a valid will—with specific directions for administration and succession—prevents the property from being declared escheated.

The validity of the testamentary disposition

Whether the instructions contained in Ana Sarmiento’s will, including the codicil and subsequent will, are sufficiently clear and binding to preclude escheatment.
Whether the continued administration by the Roman Catholic Archbishop of Manila aligns with the testamentary provisions as stipulated by the decedent.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

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END