G.R. No. L-38287 - Macadangdang vs. Court of Appeals

In 1946, Antonio Macadangdang (petitioner) and Filomena Gaviana Macadangdang (private respondent) were married after a two-year period of cohabitation.
The couple started with a modest buy-and-sell business and sari-sari store in Davao City, which later expanded into various enterprises such as merchandising, trucking, transportation, rice and corn milling, abaca stripping, and real estate.
They had six children, three of whom were adults and three minors at the time the case commenced.

Over time, despite economic stability, the physical and emotional aspects of their marriage deteriorated.
Both spouses accused one another of extramarital affairs, leading to a breakdown in their marital relationship.
The marital situation became intolerable, prompting the separation in 1965 when Filomena left for Cebu permanently.

Upon her return to Davao in 1971, after learning of her husband’s illicit affairs, Filomena instituted a complaint for legal separation on April 28, 1971, in the Court of First Instance of Davao at Tagum (Civil Case No. 109).
Antonio Macadangdang filed his answer with a counterclaim on May 31, 1971.
On February 9, 1972, Filomena petitioned for the appointment of an administrator to administer the conjugal partnership estate pending the case’s resolution, which Antonio opposed in a pleading dated February 21, 1972.

On January 4, 1973, the trial court rendered its decision. The dispositive part decreed the legal separation (or separation from bed and board) of the spouses and ordered the dissolution and liquidation of the conjugal community of property.
Because no complete inventory of the community property was available, the trial court ordered Antonio to pay Filomena PHP 10,000.00 for her support, pending the appointment of an administrator to manage the conjugal properties and to serve as guardian for the minor children.
Subsequent motions by Filomena included a motion on August 7, 1973 to withdraw PHP 10,000.00 from a lease rental and another motion on August 25, 1973, for the appointment of an administrator to prevent unlawful sequestration or clandestine transfers by Antonio.
Antonio filed motions for reconsideration regarding the appointment of the administrator on October 3, 1973 and again on October 23, 1973. The trial court denied these motions (the latter denial being issued on November 19, 1973), confirming the finality of the legal separation decision.

On December 18, 1973, Antonio elevated the case to the Court of Appeals through a petition for certiorari, prohibition, and a writ of preliminary injunction and/or temporary restraining order.
The petition sought to nullify the orders of September 20, October 13, and November 19, 1973, including the appointment of an administrator and the treatment of the January 4, 1973 decision as final and executory.
On December 21, 1973, the Court of Appeals dismissed the petition, holding that the January 4, 1973 decision had already become final and that the appointment of an administrator was proper.

On November 30, 1979, Antonio Macadangdang died, and his counsel subsequently moved to dismiss the case on February 6, 1980, arguing that the case became moot and academic.
Filomena, while noting the new circumstances, also agreed that the petitioner’s death rendered the subject petition moot and academic.
Despite the death, the Court undertook the resolution of legal issues due to their broad legal and public policy implications, particularly those involving the finality of the legal separation and the liquidation of the conjugal assets.

Whether the January 4, 1973 decision of legal separation had already become final and executory before petitioner’s subsequent actions and motions.
Whether, in a situation where the children of both spouses predecease the surviving spouse, the intestate heirs of the deceased petitioner may inherit from the innocent spouse’s share in the conjugal assets, especially under Article 106, No. 4 of the New Civil Code.
What effect the pending Special Proceedings No. 134 for settling the estate of the deceased petitioner would have on the decision in Civil Case No. 109 and on the current petition.
Whether the trial court’s appointment of an administrator was proper and whether the judgment of legal separation was incomplete for purposes of further adjudicating the division of conjugal assets.