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
Case Digest (G.R. No. L-25049)
Facts:
The case involves plaintiffs-appellants Filemon Ramirez, Monica Ramirez, and Jose Eguaras against defendants-appellees Artemio Baltazar, Susana Flores, and Artemio Diawan. The events leading to the case began on January 6, 1959, when Victoriana Eguaras executed a real estate mortgage on her property to secure a loan of P2,170.00 in favor of the spouses Baltazar and Flores. Following Victoriana's death, the mortgagees filed a petition for intestate proceedings regarding her estate on September 16, 1960, in the Court of First Instance of Laguna, which was docketed as Civil Case No. SC-99. In this petition, the mortgagees identified Filemon and Monica Ramirez as heirs. Initially, Filemon was appointed as the estate administrator, but he failed to qualify, leading to Artemio Diawan's appointment as administrator on January 16, 1961.
On April 19, 1961, the mortgagees filed a foreclosure complaint against Diawan, who was served with summons but did not respond, resulting in a default judgment against him. The case was referred to a commissioner, and Diawan, acting as a deputy clerk of court, presided over the hearing. On August 16, 1961, the court decreed the foreclosure of the property, allowing a 90-day period for payment. When the judgment was not satisfied, the property was sold at public auction to the plaintiffs for P2,888.50, and the sale was confirmed on January 26, 1962.
On February 6, 1962, the plaintiffs filed a complaint to annul the foreclosure proceedings, alleging collusion and fraud by the defendants, particularly Diawan, who failed to notify them of the foreclosure and allowed the proceedings to continue without their knowledge. The defe...