G.R. No. 147148 - Goyena vs. Ledesma-Gustilo

On July 8, 1996, Amparo Ledesma Gustilo (respondent) filed before the RTC of Makati (Special Proceeding No. N-4375) a petition to be appointed guardian of her sister, Julieta Ledesma, alleging:

Julieta, then under treatment at Makati Medical Center for old age, general debility, and post-stroke anemia, was bedridden and wheelchair-bound.
Julieta owned real and personal properties in Metro Manila and Western Visayas valued at about ₱1 million.
She was incapable of managing her person and properties and required a guardian for ongoing corporate and agricultural enterprises.
All nearest kin of full blood (including petitioner Pilar Y. Goyena, Teresa, and Loreto Ledesma) consented to the petition.
Respondent’s extensive business management experience qualified her to safeguard Julieta’s interests and ensure medical care.

Pilar Y. Goyena (petitioner), a 90-year-old close friend of over 60 years, filed an Opposition alleging Julieta’s competence and respondent’s unsuitability, attaching letters from Julieta.
On August 15, 1996, she filed an Amended Opposition, adding that:

Julieta was sane and capable of handling her affairs.
Respondent’s interests conflicted with Julieta’s (citing Sudler v. Sudler).
If a guardian were necessary, petitioner proposed herself or other named individuals.

By Decision dated October 4, 1996, the trial court found Julieta incompetent due to senility and avascular dementia and appointed respondent as guardian, reasoning that:

Respondent, as sister, was best suited to manage Julieta’s personal and business affairs.
Petitioner’s advanced age (90) rendered her physically unfit and potentially antagonistic given alleged transfers of assets.
All nearest kin had not opposed the petition, and respondent’s bond of ₱200,000 would secure performance.

The court denied petitioner’s Motion for Reconsideration on November 4, 1996, for lack of merit.

Petitioner appealed; by Decision dated June 19, 2000, the CA affirmed, holding that:

No antagonistic interests existed between respondent and Julieta as co-owners.
Petitioner failed to prove respondent’s hostility or prejudice against Julieta.
Petitioner’s concealment of Julieta’s mental state and her own age militated against her claim.

Petitioner filed a petition for review on certiorari under Rule 45, urging that:

Respondent opposed, emphasizing the factual nature of issues and proper exercise of discretion by lower courts.

Whether the Court of Appeals and the trial court erred in finding respondent suitable and free of antagonistic interests for appointment as guardian of Julieta.
Whether a petition under Rule 45 may question factual findings of lower courts concerning guardianship suitability.