G.R. No. 170787 - Pangili vs. Balatbat

On March 17, 1939, Donato Lajom, the plaintiff-appellant, filed his complaint and subsequently amended it on May 16, 1939.
The amended complaint sought a declaration that he was a natural child of the late Dr. Maximo Viola and, hence, a co-heir to the estate of Dr. Viola, alongside his half-brothers, Jose P. Viola, Rafael Viola, and Silvio Viola.
The complaint also requested, after appropriate deductions (collation, payment of debts, and accounting of fruits), the partition of the estate—allocating one-seventh to the plaintiff and two-sevenths to each defendant.

The complaint alleged that the plaintiff was a natural child, implicitly recognized and tacitly acknowledged by his father, being born in 1882 to Filomena Lajom when both parents were free and capable of contracting marriage.
It emphasized that from early childhood until after 1889, the plaintiff lived with Dr. Maximo Viola and enjoyed the status of a son not only within the family but also in the public sphere due to his father’s conduct.
The complaint further contended that the natural child status was sufficient under the liberal interpretation of Law 11 of Toro and corroborated by subsequent jurisprudence.

The plaintiff alleged that his half-brothers (the defendants) promised to deliver to him his lawful share in the deceased’s estate.
The defendants were accused of willfully, deliberately, and fraudulently concealing the existence of the plaintiff as a natural child, with the intention of depriving him of his rightful participation in the estate proceedings.
It was further alleged that the defendants partitioned the estate among themselves through a “Convenio de Partición y Adjudicación” dated October 25, 1935—an agreement supported by annexed documentary evidence.

A separate testate proceeding had been instituted in the Court of First Instance of Bulacan concerning Dr. Maximo Viola’s estate, which was already closed by March 17, 1937.
The complaint mentioned that the legal partition approved in Bulacan granted title to the defendants, yet this legal title was subject to a fiduciary duty as the defendants acted as trustees vis-à-vis the plaintiff.
The controversy included a significant jurisdictional issue, as the complaint claimed that despite some estate properties being located in different provinces, 16 parcels of land situated in Nueva Ecija furnished a basis for local jurisdiction.

The Court of First Instance of Nueva Ecija sustained the defendants’ demurrer to the complaint on July 31, 1939 and dismissed the case.
The dismissal was based on two primary grounds: a) the insufficiency of facts to constitute a cause of action (particularly since the probate jurisdiction had already been exercised in Bulacan) and b) the alleged lack of jurisdiction in Nueva Ecija due to issues concerning the location of the estate and residence of the parties.

Whether the Court of First Instance of Nueva Ecija had jurisdiction over the case, given that a substantial part of the estate’s properties were located in Nueva Ecija and yet there existed prior probate proceedings in Bulacan.
Whether the partial residence of the parties (with both plaintiff and one defendant resident in Nueva Ecija) and the location of some parcels (16 in Nueva Ecija) sufficed to confer jurisdiction.

Whether the allegations detailing the breach of trust, the implied promise by the defendants to convey the plaintiff’s rightful share of the estate, and the concealment of the plaintiff’s existence established a valid cause of action.
Whether those allegations, when liberally construed, overcome potential technical defects—such as those arising from the prior probate proceedings and the omission of certain formalities that might have been required under stricter interpretations of Law 11 of Toro.