Facts:

The case involves petitioners Cecilio C. Hernandez, Ma. Victoria C. Hernandez-Sagun, Teresa C. Hernandez-Villa Abrille, and Natividad Cruz-Hernandez against respondent Jovita San Juan-Santos. The events leading to the case began with Maria Lourdes San Juan Hernandez, also known as Lulu, who was born on February 14, 1947, to Felix Hernandez and Maria San Juan Hernandez. Maria died during childbirth, and Lulu was subsequently placed under the care of her maternal uncle, Sotero C. San Juan. Felix remarried Natividad Cruz on December 16, 1951, and they had three children: Cecilio, Ma. Victoria, and Teresa. Lulu inherited valuable real properties from the San Juan family, estimated at around P50 million in 1997.

In 1957, Lulu moved in with her father and his new family but faced difficulties due to her "violent personality," which led her to drop out of school after Grade 5. Upon reaching adulthood in 1968, she gained control over her estate, but her father continued ...

Facts:

Background and Family History

• Maria Lourdes San Juan Hernandez (Lulu) was born on February 14, 1947, to Felix Hernandez and Maria San Juan Hernandez. Maria died during childbirth, and Felix left Lulu in the care of her maternal uncle, Sotero C. San Juan.
• On December 16, 1951, Felix married Natividad Cruz, with whom he had three children: Cecilio C. Hernandez, Ma. Victoria C. Hernandez-Sagun, and Teresa C. Hernandez-Villa Abrille (petitioners).
• Lulu inherited valuable real properties from the San Juan family, conservatively estimated at P50 million in 1997.

Lulu’s Living Conditions and Property Management

• In 1957, Lulu moved in with her father and his new family. She stopped schooling after Grade 5 due to her "violent personality."
• In 1968, Lulu was given control of her estate upon reaching the age of majority. However, due to her lack of education, Felix continued to manage her properties until his death in 1993, after which petitioners took over.
• From 1968 to 1993, Felix and petitioners undertook various projects involving Lulu’s properties, including the development of the Marilou Subdivision and the sale of her 11-hectare Montalban property to Manila Electric Company for P18,206,400. Lulu was allegedly misled into signing a special power of attorney (SPA) for this sale.

Lulu’s Health and Living Conditions

• In 1998, Lulu sought help from her maternal cousin, Jovita San Juan-Santos (respondent), after discovering that petitioners were dissipating her estate. Lulu was found living in poor conditions in the basement of petitioners’ home, with a daily allowance of only P400 for food and medication.
• Lulu was severely overweight, unkempt, and suffered from tuberculosis, rheumatism, diabetes, and other complications. She lacked proper hygiene facilities and was forced to relieve herself in the garden.

Legal Proceedings

• On October 2, 1998, respondent filed a petition for guardianship in the Regional Trial Court (RTC) of San Mateo, Rizal, alleging that Lulu was incapable of managing her estate and caring for herself due to her weak mental and physical condition.
• Petitioners opposed the guardianship, claiming that Lulu was literate and aware of her actions. They also argued that the issue of Lulu’s competency had been settled in 1968 when she was emancipated.
• The RTC ruled in favor of respondent, declaring Lulu incompetent and appointing respondent as her legal guardian. The Court of Appeals (CA) affirmed this decision.

Habeas Corpus Proceedings

• In 2003, Lulu was abducted from her Marikina apartment, and petitioners were suspected of holding her captive. Respondent filed a petition for habeas corpus, which the CA granted, ruling that respondent, as Lulu’s legal guardian, was entitled to her custody.

Issue:

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Ruling:

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Ratio:

1. Incompetence and Guardianship: Under Section 2, Rule 92 of the Rules of Court, a person who, due to age, disease, weak mind, or similar causes, is incapable of managing their person or property without outside aid, may be declared incompetent and placed under guardianship. The Court found that Lulu’s medical conditions, low educational attainment, and inability to care for herself or her estate justified the appointment of a guardian.
2. Admissibility of Evidence: The opinions of Lulu’s attending physicians regarding her mental state were admissible, even though they were not psychiatrists. The trial judge’s personal observations of Lulu during her testimony also supported the finding of incompetence.
3. Appointment of Guardian: The Court upheld respondent’s appointment as Lulu’s guardian, emphasizing that guardianship is a trust relationship. Since Lulu did not trust petitioners, they were unfit to serve as her guardians.
4. Habeas Corpus: A writ of habeas corpus is proper when the rightful custody of a person is withheld. As Lulu’s legal guardian, respondent was entitled to her custody, and petitioners’ actions in abducting Lulu were unlawful.

Conclusion:

The Supreme Court denied the petitions, affirmed respondent’s appointment as Lulu’s legal guardian, and ordered petitioners to render an accounting of Lulu’s estate within 30 days. The Court also warned that criminal complaints could be filed against petitioners for their actions.