Case Digest (G.R. No. 183053)
Facts:
In In the Matter of the Intestate Estate of Cristina Aguinaldo-Suntay, Cristina died intestate on June 4, 1990, survived by her husband, Dr. Federico Suntay, and several grandchildren. Their only son, Emilio I, had predeceased Cristina in 1979, leaving three legitimate children by his then-wife Isabel Cojuangco—Isabel Cojuangco-Suntay (respondent), Margarita, and Emilio II—and two illegitimate children, Emilio A.M. Suntay III (petitioner) and Nenita, by other women. From infancy, Cristina and Federico reared and acknowledged Emilio III and Nenita as part of the family; Federico later legally adopted both. In October 1995, Isabel filed for letters of administration over Cristina’s estate in RTC Branch 78, Malolos, Bulacan (Special Proceeding Case No. 117-M-95), omitting the two illegitimate grandchildren. Federico opposed, claiming preference as surviving spouse and nominating Emilio III as administrator. After Federico’s death in 2000, Emilio III intervened, echoing his grandfatCase Digest (G.R. No. 183053)
Facts:
- Family Background and Heirs
- Cristina Aguinaldo-Suntay died intestate on June 4, 1990; she was married to Dr. Federico Suntay and their only son, Emilio Aguinaldo Suntay (Emilio I), had predeceased them in 1979.
- From Emilio I’s first (annulled) marriage to Isabel Cojuangco were born three legitimate grandchildren: Isabel Cojuangco-Suntay (respondent), Margarita, and Emilio Cojuangco-Suntay (Emilio II).
- Emilio I also had two illegitimate children by different women: Emilio A.M. Suntay III (petitioner) and Nenita Suntay TaAedo; both were reared and acknowledged by Cristina and Federico.
- Adoption and Estate Proceedings
- After Cristina’s death, Federico adopted both Emilio III and Nenita on September 27, 1993, elevating their status as his legal children.
- On October 26, 1995, respondent filed a petition for letters of administration, naming only Federico and the three legitimate grandchildren as heirs, omitting Emilio III and Nenita, and estimating the gross estate at ₱29 million.
- Federico opposed (December 21, 1995), asserting preference as surviving spouse, incomplete heir enumeration, and nominating Emilio III as administrator in his stead.
- The RTC (Branch 78, Malolos) granted Emilio III leave to intervene, and on November 9, 2001 appointed him administrator upon posting a ₱200,000 bond.
- The Court of Appeals (CA) reversed on June 15, 2010 (G.R. No. 183053), revoking Emilio III’s letters and appointing respondent administratrix, citing Article 992’s bar on illegitimate heirs and the lapsed suspensive nomination.
- Supreme Court Appeal
- Emilio III’s motion for reconsideration was denied by the CA.
- He then filed a petition for certiorari under Rule 45, raising:
- Whether Article 992 of the Civil Code applies to the appointment of an estate administrator; and
- Whether, given his rearing and adoption, Article 992 should bar his appointment.
Issues:
- Does Article 992 of the Civil Code bar an illegitimate (but adopted) grandchild from appointment as administrator of the grandmother’s intestate estate?
- Under the undisputed facts—where Emilio III was reared by the decedent and legally adopted—should Article 992 operate to disqualify him as administrator?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)