Case Digest (G.R. No. 75005-06)
Facts:
Jose Rivera v. Intermediate Appellate Court and Adelaido J. Rivera, G.R. Nos. 75005-06, February 15, 1990, Supreme Court First Division, Cruz, J., writing for the Court.On May 30, 1975, a prominent Mabalacat, Pampanga resident named Venancio Rivera died. On July 28, 1975, Jose Rivera filed a petition for the issuance of letters of administration over the estate (SP No. 1076), claiming to be the only surviving legitimate son of the decedent. Adelaido J. Rivera opposed that petition, denying Jose’s filiation and asserting that the decedent was his own father who left two holographic wills; Adelaido then filed for probate of those wills on November 7, 1975 (SP No. 1091). The two cases were consolidated on November 11, 1975, and Adelaido was appointed special administrator.
After a joint trial before the Regional Trial Court, Judge Eliodoro B. Guinto found that the Venancio Rivera who married Maria Jocson (1942) and fathered Adelaido and six other children was not the same person who allegedly married Maria Vital in 1928 and sired Jose Rivera. The trial court admitted the holographic wills and held Jose had no claim to the estate. The then Intermediate Appellate Court (IAC) affirmed the trial court’s decision on appeal.
Jose elevated the IAC ruling to the Supreme Court by a petition (the petition now before the Court seeks reversal of the respondent court’s judgment). At trial Jose offered his parents’ marriage certificate and his baptismal certificate and testimony claiming identity with the decedent, while Adelaido produced his own and his siblings’ birth certificates, a baptismal certificate for the decedent showing different parents, testimony about the decedent’s introduction of Maria Jocson as wife d...(Pro-only)
Issues:
- Did the trial court and the Intermediate Appellate Court err in finding that Jose Rivera was not the son of the decedent Venancio Rivera (i.e., whether the decedent’s identity/filiation was as claimed by Jose)?
- Could Jose Rivera, as a person found not to be an heir (a stranger), validly contest the holographic wills so as to trigger the three-witness requirement of...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)