Case Digest (G.R. No. 182645)
Facts:
In the Matter of the Heirship (Intestate Estates) of the Late Hermogenes Rodriguez, Antonio Rodriguez, Macario J. Rodriguez, Delfin Rodriguez and Consuelo M. Rodriguez and Settlement of their Estates, Rene B. Pascual, Petitioner v. Jaime M. Robles, G.R. No. 182645, December 04, 2009, Supreme Court Third Division, Chico‑Nazario, J., writing for the Court.Petitioners in the special proceeding before the Regional Trial Court (RTC) were Henry F. Rodriguez, Certeza F. Rodriguez and Rosalina R. Pellosis, who on 14 September 1989 filed Special Proceeding No. IR‑1110 seeking declaration of heirship and appointment of administrator for the estates of several deceased Rodriguez relatives (initially Hermogenes and Antonio; later amended to include Macario J., Delfin M. and Consuelo M.). They alleged descent from Antonio and, as to Hermogenes, that Hermogenes died without issue and Antonio was his sole heir.
At the initial hearing on 14 November 1989 there were no oppositors and the RTC entered a general default against the world (except the Republic). After presentation of evidence before a commissioner, the RTC issued a Partial Judgment on 31 May 1990 declaring Henry, Certeza and Rosalina as heirs in Antonio’s line and appointing Henry administrator (regular for some estates and special for Hermogenes). Henry posted bond and assumed office.
Subsequently six groups or individuals entered oppositions, including groups led by Judith Rodriguez and Carola Favila‑Santos, and individual oppositors Jaime M. Robles, Florencia Rodriguez, Victoria Rodriguez, and Bienvenido Rodriguez. Jaime Robles claimed heirship to Hermogenes, sought appointment as regular administrator of Antonio’s and Hermogenes’ estates, and sought authority to sell a parcel covered by OCT No. 12022 (Manggahan, Pasig).
On 15 December 1994 the RTC issued an order declaring Jaime Robles an heir and appointing him regular administrator of the entire estate of Hermogenes and permitting the sale of the Manggahan property. On 27 April 1999 the RTC rendered a decision recognizing Carola Favila‑Santos and co‑heirs as heirs of Hermogenes while reiterating its earlier findings as to Henry, Certeza and Rosalina; it dismissed oppositions by Robles and others for failing to substantiate heirship. On 13 August 1999 the RTC issued an Amended Decision reversing the finding in favor of Carola Favila‑Santos and instead declaring Henry, Certeza and Rosalina as heirs of Hermogenes; the Amended Decision also reaffirmed dismissal of Robles’ opposition.
Several aggrieved parties sought appellate relief: Florencia Rodriguez pursued review (G.R. No. 142477) which this Court denied on 5 September 2000; Carola Favila‑Santos’ challenge (G.R. No. 140271) was denied on 22 February 2000. Jaime Robles filed only a notice of appeal on 12 October 1999 but failed to file the required record on appeal; the RTC on 22 November 1999 denied the notice for failure to file the record. Because the appeal was not perfected, the 13 August 1999 Amended Decision became final and executory and a Certificate of Finality was issued on 17 January 2000.
Rene B. Pascual later appeared as a purchaser of a parcel from the Rodriguez estate (Absolute Sale executed 19 January 2005 and approved by the RTC) and intervened in the proceedings. Jaime Robles then attempted to secure relief by filing a petition for review under Rule 45 directly with the Supreme Court, which the Court declined to take cognizance of and instead referred the matter to the Court of Appeals (CA). Despite the unperfected appeal and finality of the RTC Amended Decision, the CA assumed jurisdiction and on 16 April 2002 r...(Pro-only)
Issues:
- Did the Court of Appeals have jurisdiction to entertain and decide the matter despite Jaime Robles’ failure to perfect an appeal (i.e., failure to file the record on appeal) from the RTC’s 13 August 1999 Amended Decision?
- Should the Court of Appeals’ 16 April 2002 decision and the RTC’s order expunging the records be set aside and the RTC’s 13 August 199...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)