Case Digest (G.R. No. 166470)
Facts:
Cecilio C. Hernandez, Ma. Victoria C. Hernandez‑Sagun, Teresa C. Hernandez‑Villa Abrille and Natividad Cruz‑Hernandez, petitioners, vs. Jovita San Juan‑Santos, respondent, G.R. No. 166470 and G.R. No. 169217, August 07, 2009, Supreme Court First Division, Corona, J., writing for the Court.Maria Lourdes San Juan Hernandez ("Lulu") was born February 14, 1947; her mother died in childbirth and her father, Felix Hernandez, left her in the care of her maternal uncle. Felix later married Natividad Cruz (mother of petitioners) and had three children—petitioners Cecilio, Ma. Victoria and Teresa—while Lulu inherited substantial San Juan family real properties as sole testate heir. Lulu moved to live with her father’s family in 1957, did not finish elementary schooling, but was formally given control of her estate upon reaching majority in 1968; in practice Felix continued administering her properties until his death in 1993, after which petitioners assumed administration.
During petitioners’ informal administration various transfers and arrangements affecting Lulu’s properties occurred: a 1974 transfer relating to the Marilou/Marilou Village Subdivision (claimed by petitioners to belong to Felix and Natividad), a 1995 sale by SPA of an 11‑hectare Montalban parcel to Manila Electric Company for P18,206,400 (the SPA executed by Lulu allegedly without full understanding), and proposed leases of other properties. In September 1998 Lulu’s cousin Jovita San Juan‑Santos (respondent) learned Lulu was confined to poor living conditions, malnourished and ill; respondent’s demand for inventory and accounting from petitioners was ignored.
Respondent filed a petition for guardianship in the Regional Trial Court (RTC), San Mateo, Rizal, Branch 76 on October 2, 1998, alleging Lulu was incapable of caring for herself and managing her estate due to weak mind and illness; petitioners intervened, contending Lulu’s competency had been settled by the 1968 emancipation order and arguing questions of administration and alleged sales were beyond a guardianship proceeding (some transactions barred by prescription). At trial Lulu testified about her family and ownership; medical evidence from attending physicians (cardiologist‑internist, diabetologist‑internist, general practitioner and surgeon) documented severe physical ailments and assessed Lulu’s intelligence as below average and mental state fragile.
On September 25, 2001 the RTC declared Lulu incompetent and appointed respondent as guardian over person and property on a P1,000,000 bond. Petitioners’ motion for reconsideration was denied. They appealed to the Court of Appeals (CA) as CA‑G.R. CV No. 75760. On December 29, 2004 the CA affirmed the RTC in toto, finding respondent proved Lulu needed assistance and that respondent was the proper guardian because Lulu trusted her; the CA noted guardianship is a trust relationship. Petitioners filed a petition for review under Rule 45 docketed G.R. No. 166470.
Separately, after Lulu moved to a Marikina residence and was provided attendants, she was abducted in November 2003; PACER found petitioners were keeping her in Rodriguez, Rizal. Respondent filed a petition for habeas corpus in the CA on December 15, 2003; on April 26, 2005 the CA granted the writ, ordering custody to respondent. Petitioners’ motion for reconsideration was denied (July 12, 2005) and they sought review in this Court by Rule 45 docketed G.R. No. 169217; the two petitions were consolidated.
Before the Court, petitioners argued the physicians’ opinions were inadmissible because they were not psychiatrists and that Lulu sho...(Subscriber-Only)
Issues:
- May this Court disturb the trial and appellate courts’ factual findings that Lulu is an incompetent requiring a judicial guardian?
- Were the opinions of Lulu’s attending physicians, who were not psychiatrists, admissible and sufficient to support a finding of incompetency?
- Was the appointment of respondent Jovita San Juan‑Santos as judicial guardian over Lulu’s person and property proper?
- Was issuance of the writ of habeas corpus in favor of respo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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