Case Digest (G.R. No. 149013)
Facts:
In Mauricio Sayson et al. v. Court of Appeals et al. (G.R. Nos. 89224-25, January 23, 1992), Eleno and Rafaela Sayson had five children: Mauricio, Rosario, Basilisa, Remedios and Teodoro. Eleno died on November 10, 1952, and Rafaela on May 15, 1976. Teodoro married Isabel Bautista; he died on March 23, 1972, and she on March 26, 1981. Their properties remained in the possession of Delia, Edmundo and Doribel Sayson, who claimed to be their children. On April 25, 1983, Mauricio, Rosario, Basilisa, Remedios and Juana C. Bautista filed Civil Case No. 1030 in the Regional Trial Court (RTC) of Albay, Branch 13, seeking partition and accounting of Teodoro’s and Isabel’s intestate estate. Delia, Edmundo and Doribel resisted, asserting succession rights as lawful descendants. On July 11, 1983, the three filed Civil Case No. 1042 in RTC Albay, Branch 12, for partition and accounting of Eleno’s and Rafaela’s estate, claiming Delia and Edmundo as adopted children of Teodoro and Isabel by deCase Digest (G.R. No. 149013)
Facts:
- Genealogical and death facts
- Eleno and Rafaela Sayson had five children: Mauricio, Rosario, Basilisa, Remedios, and Teodoro.
- Eleno died on November 10, 1952; Rafaela on May 15, 1976.
- Teodoro and Isabel’s lineage
- Teodoro married Isabel Bautista; he died March 23, 1972, and she died March 26, 1981.
- Their properties were possessed by Delia, Edmundo, and Doribel Sayson, who claimed to be their children.
- Civil Case No. 1030 (Branch 13, RTC Albay)
- April 25, 1983: Mauricio, Rosario, Basilisa, Remedios, and Juana Bautista filed for partition and accounting of Teodoro and Isabel’s intestate estate.
- Delia, Edmundo, and Doribel resisted, claiming succession rights as lawful descendants.
- Civil Case No. 1042 (Branch 12, RTC Albay)
- July 11, 1983: Delia, Edmundo, and Doribel filed for partition of Eleno and Rafaela’s intestate estate against the four surviving Sayson children.
- They asserted that Delia and Edmundo were legally adopted by Teodoro and Isabel (decree dated March 9, 1967) and Doribel was their legitimate daughter (birth certificate dated February 27, 1967).
- Trial court decisions
- May 26, 1986 (Santelices, J.): Declared Delia and Edmundo legally adopted; Doribel legitimate; all entitled to inherit from grandparents by right of representation.
- September 30, 1986 (Sanez, J.): Dismissed Case No. 1030, excluding petitioners from Teodoro and Isabel’s estate.
- Court of Appeals decision (February 28, 1989)
- Civil Case No. 1030 (CA-G.R. No. 11541): Affirmed dismissal.
- Civil Case No. 1042 (CA-G.R. No. 12364): Modified to disqualify Delia and Edmundo from inheriting from Eleno and Rafaela; affirmed in other respects.
- Petition for review by certiorari
- Petitioners challenged the CA ruling, arguing invalid adoption (due to Doribel’s pre-adoption birth) and Doribel’s illegitimacy.
- They also contended collateral attack on adoption and legitimacy findings was improper and untimely.
Issues:
- Capacity of Delia and Edmundo to inherit as adopted children of Teodoro and Isabel.
- Legitimacy of Doribel as daughter of Teodoro and Isabel.
- Whether findings on adoption and legitimacy can be collaterally attacked in partition proceedings.
- Whether Delia and Edmundo, as adopted children, have right of representation to inherit from Eleno and Rafaela.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)