Case Digest (G.R. No. 12103)
Facts:
The case of Juan Guting, Administrator of the Estate of the Deceased Narciso Guting, vs. Julian Ramboa et al. was initiated in the Court of First Instance of Tarlac. The action aimed to settle and divide the estate of Narciso Guting, who passed away in January 1915. The respondents, Julian Ramboa and others, opposed the division, claiming entitlement to one-half of the estate as they were the legitimate heirs of Margarita Dancel, Narciso Guting's first wife. The facts presented in the case reveal that Narciso Guting and Margarita Dancel were legally married in April 1858 and lived together until 1900, when Margarita died without leaving any children. Subsequently, in November 1901, Narciso married Antonia Guiang. The respondents are the children of Margarita Dancel's siblings, who had all passed away. The contested estate included properties that the respondents claimed were ganancial property acquired during the marriage of Narciso and Margarita. The lower court foun...
Case Digest (G.R. No. 12103)
Facts:
Marriage of Narciso Guting and Margarita Dancel:
Narciso Guting and Margarita Dancel were legally married in April 1858 and lived together as husband and wife until 1900. Margarita Dancel died on October 11, 1900, without leaving any children.Subsequent Marriage of Narciso Guting:
In November 1901, Narciso Guting married Antonia Guiang. Narciso Guting died in January 1915.Heirs of Margarita Dancel:
Margarita Dancel had two sisters (Juana Dancel and Andrea Dancel) and one brother (Pablo Dancel), all of whom had died. The defendants are their children:- Julian Rombaoa, Miguel Rombaoa, and Apolonia Rombaoa (children of Juana Dancel).
- Matias Pagarigan (son of Andrea Dancel).
- Jorge Dancel, Isaac Dancel, Gerarda Dancel, Teodorico Dancel, Petra Dancel, and Apolonia Dancel (children of Pablo Dancel).
Property in Question:
The property in dispute was acquired during the marriage of Narciso Guting and Margarita Dancel (1858–1900), except for two parcels:- The land mentioned in the proyecto de liquidacion marked with the letter L.
- The land described in the Torrens title (Exhibit 3).
Disputed Fact:
The main issue was whether the property described in the proyecto de liquidacion was acquired during the marriage of Narciso Guting and Margarita Dancel.Lower Court’s Decision:
The lower court ruled that all the property, except the two parcels mentioned, was ganancial property. It ordered the administrator, Juan Guting, to prepare a division of the estate, allocating one-half to the heirs of Margarita Dancel and the other half to the heirs of Narciso Guting.
Issue:
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Ruling:
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Ratio:
Finality of Judgment:
A judgment is not final if it requires further actions or leaves unresolved issues. In this case, the lower court’s judgment was not final because it ordered the administrator to prepare a division of the estate, which could lead to further disputes and proceedings.Partition of Property:
Under Act No. 190, Sections 753 and 762, if the parties do not expressly ask for a partition, the court must adjudicate the inheritance pro indiviso, designating the aliquot parts corresponding to each heir. However, the Court did not definitively rule on this issue, leaving it to the lower court to address in further proceedings.Ganancial Property:
Property acquired during a marriage is presumed to be ganancial, and upon the death of one spouse, the surviving spouse and the heirs of the deceased spouse are entitled to their respective shares. The lower court’s finding that the property was ganancial was not overturned.
Concurring and Dissenting Opinion (Fisher, J.)
Concurrence:
Justice Fisher agreed with the majority’s decision to remand the case to the lower court, as the judgment was not final.Dissent:
Justice Fisher dissented on the issue of partition, arguing that if the parties do not expressly ask for a partition, the court must adjudicate the inheritance pro indiviso. He also noted that the disputed questions could be raised again in future proceedings.