Title
Ramirez vs. Baltazar
Case
G.R. No. L-25049
Decision Date
Aug 30, 1968
Plaintiffs were granted heirship rights and permitted to initiate proceedings without a qualified administrator, as defendants are estopped from contesting their claim.
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Case Digest (G.R. No. L-25049)

Facts:

  • The case Ramirez v. Baltazar (G.R. No. L-25049) was decided by the Supreme Court of the Philippines on August 30, 1968.
  • Plaintiffs-appellants: Filemon Ramirez, Monica Ramirez, and Jose Eguaras.
  • Defendants-appellees: Artemio Baltazar, Susana Flores, and Artemio Diawan.
  • The dispute arose from the death of Victoriana Eguaras, who executed a real estate mortgage on January 6, 1959, to secure a loan for Baltazar and Flores.
  • After her death, the mortgagees initiated intestate proceedings on September 16, 1960, claiming Filemon and Monica Ramirez were the heirs.
  • Artemio Diawan was appointed as the estate administrator after Filemon was deemed unqualified.
  • On April 19, 1961, the mortgagees began foreclosure proceedings against Diawan, who did not respond, leading to a default judgment in favor of the mortgagees.
  • The property was auctioned and sold to the plaintiffs, who sought to annul the foreclosure, alleging collusion between the administrator and the mortgagees.
  • The lower court dismissed their complaint, stating the plaintiffs lacked legal capacity to sue until their heirship was formally recognized.
  • The plaintiffs appealed the dismissal.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the plaintiffs-appellants, stating that the defendants-appellees were estopped from disputing the heirship of Filemon and Monica Ramirez.
  • The Court affirmed that the heirs could file the action based on alleged collusion, allowing them to have standing despite the lack of formal heirship declaration.
  • The Court reversed the lower court's dismissal of the complaint and remanded ...(Unlock)

Ratio:

  • The Court emphasized that the right to succession is automatically granted to heirs upon the decedent's death, regardless of formal judicial acknowledgment.
  • It noted that the defendants-appellees had previously recognized the plaintiffs as heirs in their intestate proceedings, preventing them from later contesting this status.
  • The Court referenced Pascual v. Pascual, allowing heirs to act in place of an administra...continue reading

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