Case Digest (G.R. No. 163707) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Michael C. Guy v. Court of Appeals, petitioner Michael C. Guy, one of the heirs of the late Sima Wei (also known as Rufino Guy Susim), challenged the proceedings in Special Probate Case No. 4549 before the Regional Trial Court of Makati City, Branch 138. On June 13, 1997, private respondents Karen Oanes Wei and Kamille Oanes Wei, represented by their mother Remedios Oanes, filed a petition for letters of administration over the intestate estate of Sima Wei, who died on October 29, 1992, leaving properties valued at ₱10,000,000.00. They alleged that they were duly acknowledged illegitimate children of the decedent and sought appointment of a regular administrator, with petitioner as special administrator in the interim. Attached to their petition was a Certification Against Forum Shopping signed by their counsel. Petitioner opposed, invoking Rule 74, Section 1 of the Rules of Court to settle the estate without letters of administration, objecting to the form of the certificati Case Digest (G.R. No. 163707) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for letters of administration
- On June 13, 1997, minors Karen Oanes Wei and Kamille Oanes Wei, represented by their mother Remedios Oanes, filed Sp. Proc. No. 4549 for letters of administration over the intestate estate of Sima Wei (a.k.a. Rufino Guy Susim), who died October 29, 1992, leaving an estate valued at ₱10,000,000.00.
- Private respondents alleged they are duly acknowledged illegitimate children and prayed for the appointment of a regular administrator and, in the meantime, for Michael C. Guy (petitioner) as Special Administrator. They attached a Certification Against Forum Shopping signed by their counsel.
- Motions to dismiss and oppositions
- Petitioner Michael C. Guy filed a Comment/Opposition arguing no debts existed, the estate could be settled under Rule 74, Section 1, and that private respondents should have established their filiation during Sima Wei’s lifetime pursuant to Family Code Article 175.
- The other heirs filed a Joint Motion to Dismiss on the ground that the Certification Against Forum Shopping was signed by counsel and not by private respondents or their mother (Rule 7, Section 5). In a Supplemental Motion, they further alleged that private respondents executed a June 7, 1993 Release and Waiver of Claim in exchange for ₱300,000.00 and educational assistance, thereby extinguishing any succession rights.
- Proceedings in the RTC and CA
- The RTC denied all motions to dismiss, ruling the Release and Waiver was invalid for lack of proof that Remedios was the minors’ duly constituted guardian and applying a liberal interpretation of the forum-shopping certification rule. A motion for reconsideration was likewise denied.
- Petitioner filed a certiorari petition in the Court of Appeals (CA-G.R. SP No. 79742). The CA, in a January 22, 2004 Decision and May 25, 2004 Resolution, denied the petition for certiorari, affirmed the RTC orders, and directed the trial court to resolve the controversy over private respondents’ illegitimate filiation.
Issues:
- Whether the petition for letters of administration must be dismissed for failure to comply with the rules on certification of non-forum shopping.
- Whether the June 7, 1993 Release and Waiver of Claim precludes private respondents from claiming their successional rights.
- Whether private respondents are barred by prescription from proving their filiation as illegitimate children.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)