Case Digest (G.R. No. 233999) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dalisay E. Ocampo et al. v. Renato M. Ocampo and Erlinda M. Ocampo (G.R. No. 187879, July 5, 2010), petitioners Dalisay E. Ocampo (widow) and her children Vince, Melinda Carla, and Leonardo Jr. sought the judicial settlement of the estates of their late father Leonardo Ocampo (d. January 23, 2004) and their grandparents Sps. Vicente (d. December 19, 1972) and Maxima Ocampo (d. February 19, 1996), who died intestate and without debts. On June 24, 2004, they filed in the Regional Trial Court (RTC), Branch 24, Biñan, Laguna, Sp. Proc. No. B-3089, alleging that respondents Renato and Erlinda (Leonardo’s siblings) had been collecting estate income to the petitioners’ exclusion and praying for an administrator’s appointment. Respondents opposed, contending that two estates could not be settled together, and counter-petitioned to be appointed special joint administrators. On June 15, 2006, the RTC named Renato and Dalisay as special administrators, each to post a ₱200,000 bond. Resp Case Digest (G.R. No. 233999) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationships
- Petitioners Dalisay E. Ocampo (widow), Vince E. Ocampo, Melinda Carla E. Ocampo, and Leonardo E. Ocampo, Jr. (children) are heirs of the late Leonardo M. Ocampo.
- Respondents Renato M. Ocampo and Erlinda M. Ocampo are Leonardo’s siblings and co-heirs of their parents, Vicente and Maxima Ocampo.
- Decedents’ Estates and Initial Petition
- Vicente and Maxima died intestate (1972 and 1996), leaving real properties in Biñan, Laguna, and no debts or will.
- On June 24, 2004, petitioners filed a combined petition for judicial settlement of the estates of Vicente and Maxima and of Leonardo (Sp. Proc. No. B-3089).
- Trial Court Proceedings and Special Administrators
- Respondents opposed the combined petition and counter-petitioned to be appointed special joint administrators of Vicente and Maxima’s estate.
- June 15, 2006 Order: RTC appointed Renato and Dalisay as special joint administrators, each to post a ₱200,000 bond.
- Respondents’ August 1, 2006 motion for reconsideration sought to exclude Dalisay; RTC on February 16, 2007 revoked Dalisay and appointed Erlinda as co-administrator.
- Petitioners repeatedly moved for inventory and accounting; respondents moved for bond exemption, pending which they claimed they could not perform duties.
- October 15, 2007 motion: petitioners sought revocation of special administration and appointment of regular administratrix or partition.
- March 13, 2008 RTC Order: revoked respondents’ special admin roles for failure to post bond and render accounts; appointed Melinda as regular administratrix (₱200,000 bond), and allowed judicial partition thereafter.
- Court of Appeals and Supreme Court Invocation
- Respondents filed Rule 65 petition (certiorari) before CA, alleging grave abuse: RTC revoked them without ruling on bond-exemption motion and appointed Melinda without hearing.
- December 16, 2008 CA Decision: granted certiorari, annulled March 13, 2008 RTC Order for grave abuse of discretion.
- April 30, 2009 CA Resolution denied motion for reconsideration.
- Petitioners elevated the case to the Supreme Court via Rule 45 petition for review on certiorari.
Issues:
- Whether the RTC gravely abused its discretion in revoking respondents as special administrators for failure to post bond and render inventory and accounts.
- Whether the RTC abused its discretion by appointing Melinda Carla E. Ocampo as regular administratrix without proper petition, hearing, or adherence to the order of preference.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)