Title
Frianela vs. Banayad, Jr.
Case
G.R. No. 169700
Decision Date
Jul 30, 2009
Petitioner sought probate of a holographic will; respondent contested with later wills. SC dismissed case due to RTC's lack of jurisdiction, as estate's value was unalleged, voiding all proceedings.

Case Digest (G.R. No. 169700)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties
    • Petitioner: Apolonia Banayad Frianela, named as devisee in the decedent’s holographic will.
    • Respondent: Servillano Banayad, Jr., a cousin of the petitioner who counter-petitioned for the allowance of other holographic wills.
    • Decedent: Moises F. Banayad, who left behind several wills and properties, and whose estate is the subject of the probate proceedings.
  • Petition and Initiation of Proceedings
    • On June 3, 1991, following the death of Moises F. Banayad, petitioner filed Sp. Proc. No. 3664-P before the Regional Trial Court (RTC) of Pasay City seeking the allowance of a holographic will dated November 18, 1985.
    • The petition alleged that, as the named devisee, the petitioner was bequeathed the following properties:
      • A parcel of land described in Transfer Certificate of Title No. 9741, located in Pasay City.
      • Religious images (Oracion del Huerto and Pieta, including the crown).
      • All personal belongings of the decedent.
    • The original petition contained crucial averments regarding the testator’s capacity at the time of execution and details of the bequeathed properties but failed to state the gross value of the estate.
  • Opposition and Counter-Petition
    • Respondent filed his opposition and, in addition, counter-petitioned for the allowance of two other holographic wills dated September 27, 1989 and September 28, 1989.
    • The dispute then focused on the conflicting holographic wills and the corresponding testimonial and documentary evidences presented by both parties.
  • Trial Court Decision and Subsequent Developments
    • On September 29, 1995, the RTC rendered a decision declaring the holographic will of September 27, 1989 as effective.
      • The RTC ruled that the September 27, 1989 will revoked the earlier November 18, 1985 will.
      • It granted the allowance of the former and appointed respondent as administrator of Moises’ estate, issuing letters testamentary and administration accordingly.
    • On appeal, the Court of Appeals (CA) in its June 17, 2005 Decision modified the RTC ruling by holding that the September 27, 1989 will only revoked the November 18, 1985 will with respect to the testamentary disposition of the decedent’s real property.
    • Petitioner filed a motion for reconsideration which was denied on August 17, 2005, prompting her to elevate the case to the Supreme Court via a petition for review on certiorari under Rule 45.
  • Jurisdictional Allegations
    • A crucial observation by the Supreme Court related to the exercise of jurisdiction:
      • The RTC focused entirely on the merits without first determining whether it had proper jurisdiction over Sp. Proc. No. 3664-P.
      • At the time of filing, the applicable law (Sections 19 and 33 of B.P. Blg. 129) required the petition to include an allegation of the gross value of the estate.
    • The petitioner’s original pleading lacked any statement or calculation of the estate’s gross value.
      • This deficiency meant that it was unclear whether the RTC, which exercises exclusive jurisdiction in probate matters where the estate exceeds P20,000, was the proper forum.
    • The RTC’s assumption of jurisdiction despite the absence of the requisite value allegation was deemed a gross error.
    • The Court further noted that the issue of jurisdiction may be raised de officio at any stage of the proceedings, even on appeal.
  • Legal and Comparative Context
    • The decision referenced the principle that jurisdiction is determined by the allegations in the pleadings and the law in force at the time the action is instituted.
    • The Court cited similar cases and doctrines, particularly highlighting the inapplicability of the estoppel by laches doctrine in this context, since:
      • The exception applies only in exceptional cases, usually when invoked during the execution stage of a final decision (as in Tijam v. Sibonghanoy and Figueroa v. People).
      • The principle of estoppel by laches generally cannot bind the government.
    • The decision provided a comprehensive discourse on the proper application of jurisdiction statutes governing probate proceedings as amended by relevant laws.

Issues:

  • Jurisdictional Competence
    • Whether the Regional Trial Court had proper jurisdiction to hear and decide the petition given that the original pleading did not include a statement of the gross value of the decedent’s estate.
    • Whether the absence of the required jurisdictional averment (i.e., the gross value) rendered the probate proceedings unauthorized from the outset.
  • Application of Jurisdictional Rules and Doctrines
    • Whether the trial court should have dismissed the case for lack of jurisdiction upon discovering the insufficient pleading with regard to the estate’s value.
    • Whether the Court of Appeals erred by not raising the jurisdictional issue on appeal, given that such a defect can be raised at any stage of the proceedings.
  • Relevance of Estoppel by Laches
    • Whether the equitable doctrine of estoppel by laches, as cited in Tijam and clarified in Figueroa, could apply to bar the petition based on the delay in invoking the jurisdictional issue.
    • Whether the government is exempt from being adversely affected by the estoppel by laches principle in matters concerning jurisdiction.
  • Effect on Collateral Issues
    • Although the petition also raised issues regarding the validity and effect of the holographic wills (e.g., allegations of undue influence, non-compliance with provisions of the Civil Code), whether these issues become moot given the defective jurisdictional basis of the proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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