Case Digest (G.R. No. 83484) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 83484, decided on February 12, 1990 under the 1987 Constitution, petitioner Celedonia Solivio, maternal aunt and administratrix, sought review of the Court of Appeals’ January 26, 1988 decision in CA-GR CV No. 09010, which had affirmed the Iloilo RTC Branch 26 judgment in Civil Case No. 13207 ordering partition of the estate of the late novelist Esteban Javellana, Jr. The decedent died intestate on February 26, 1977 without spouse, descendants, ascendants, siblings, nephews or nieces, leaving two surviving relatives: Celedonia, his mother’s half-sister, and respondent Concordia Javellana-Villanueva, his father’s sister. Esteban inherited various parcels from his mother, Salustia Solivio, including a La Paz house and several Iloilo lands, and had expressed his plan to create a foundation in her name. After Esteban’s death, Celedonia and Concordia orally agreed to organize the Salustia Solivio Vda. de Javellana Foundation for educational scholarships. Celedonia then fi Case Digest (G.R. No. 83484) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Deceased
- The late Esteban S. Javellana, Jr. died on February 26, 1977, a bachelor without descendants, ascendants, siblings, nephews or nieces.
- His only surviving relatives were:
- Celedonia Solivio (petitioner) – maternal aunt, half-sister of his mother.
- Concordia Javellana-Villanueva (respondent) – paternal aunt, sister of his deceased father.
- Estate and Decedent’s Intent
- Estate comprised various parcels of land and a house and lot in La Paz, Iloilo City, inherited by Esteban from his mother, Salustia Solivio.
- During his lifetime, Esteban expressed a desire to place his estate in a foundation to honor his mother and fund scholarships for indigent but deserving students.
- Proceedings in the Court Below
- March 8, 1977 – Celedonia filed Special Proceeding No. 2540 for appointment as special administratrix, sole heir declaration, and eventual foundation formation.
- April 3, 1978 – The trial court (CFI Branch II, now RTC Branch 23) declared Celedonia sole heir and instructed her to expedite settlement.
- July 17, 1981 – The “Salustia Solivio Vda. de Javellana Foundation” was registered; Celedonia sold estate properties to pay obligations and fund the foundation.
- October 27, 1978 – Concordia’s motion to intervene in Special Proceeding No. 2540 was denied for tardiness.
- January 7, 1980 – Concordia filed Civil Case No. 13207 (partition, reconveyance of ownership and possession, and damages) in RTC Branch 26.
- September 3, 1984 – RTC Branch 26 rendered judgment in favor of Concordia ordering partition.
- January 26, 1988 – Court of Appeals (CA-GR CV No. 09010) affirmed the trial court decision in toto.
- Celedonia filed this petition for review on the following issues.
Issues:
- Jurisdiction
- Whether RTC Branch 26 had jurisdiction to entertain Concordia’s partition suit while probate proceedings (Spl. Proc. No. 2540) were pending in Branch 23.
- Extrinsic Fraud
- Whether Concordia was prevented by extrinsic fraud from intervening in Spl. Proc. No. 2540.
- Reserva Troncal
- Whether the estate was subject to reserva troncal in favor of Celedonia as a relative within the third degree on the maternal side.
- Foundation Agreement
- Whether Concordia could recover her share of the estate after agreeing to place it in the “Salustia Solivio Vda. de Javellana Foundation.”
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)