Case Digest (G.R. No. L-18692) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lourdes L. Dorotheo vs. Court of Appeals, Nilda D. Quintana, G.R. No. 108581, decided on December 8, 1999, petitioner Lourdes Legaspi Dorotheo filed in 1977 a special proceeding in Quezon City for the probate of the last will and testament of the late Alejandro Dorotheo, whom she claimed to have cared for before his death. The Regional Trial Court admitted the will in 1981; private respondents, Alejandro’s legitimate children Vicente, Jose, and Nilda Quintana (as attorney-in-fact), did not appeal. In 1983, they moved to declare the will intrinsically void, and in January 1986 the trial court granted the motion, voiding the testamentary provisions and directing intestate distribution to themselves. Petitioner’s motion for reconsideration was denied; her appeal to the Court of Appeals was dismissed in early 1989 for failure to file a brief, becoming final and executory on February 3, 1989. Execution was thereafter issued. In November 1990, the trial court sua sponte set aside t Case Digest (G.R. No. L-18692) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Alejandro Dorotheo and Aniceta Reyes were husband and wife; Aniceta died in 1969 without settling her estate.
- Their legitimate children are Nilda D. Quintana (for herself and as attorney-in-fact of Vicente and Jose Dorotheo). Lourdes L. Dorotheo (petitioner) claims to have cared for Alejandro before his death but admits they were not married.
- Probate Proceedings
- In 1977, petitioner filed a special proceeding for the probate of Alejandro’s last will and testament.
- In 1981, the Regional Trial Court (RTC) admitted the will to probate; private respondents did not appeal.
- Intrinsic Void Declaration
- In 1983, private respondents filed a “Motion To Declare The Will Intrinsically Void.”
- On January 30, 1986, the RTC granted the motion, declaring the will intrinsically void, naming respondents as the only heirs, and ordering distribution of both spouses’ estates according to intestacy laws.
- Post-Judgment and Collateral Proceedings
- Petitioner’s motion for reconsideration was denied; her appeal to the Court of Appeals (CA) was dismissed in January 1989 for failure to file a brief. The dismissal became final and executory on February 3, 1989.
- Execution proceedings were initiated; respondents sought surrender and cancellation of Transfer Certificates of Title. Petitioner refused.
- On November 29, 1990, RTC Judge Angas set aside the January 30, 1986 order as interlocutory. A motion for reconsideration was denied February 1, 1991.
- Private respondents petitioned the CA under Rule 65, which on May 16, 1991 nullified Judge Angas’s orders. Petitioner then filed a petition for review under Rule 45 before the Supreme Court.
Issues:
- May a last will and testament, admitted to probate but later declared intrinsically void by a final and executory order, still be given effect?
- Can a designated trial court judge set aside or disturb a final and executory order of a superior court?
- Does petitioner, not being the lawful spouse of the decedent, have any right to compensation or appointment as executrix/administratrix?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)