Case Digest (G.R. No. 183053)
Facts:
The controversy arose from the intestate estate of Cristina Aguinaldo-Suntay, who died on June 4, 1990, survived by her husband, Dr. Federico Suntay, and five grandchildren: three legitimate (including respondent Isabel Cojuangco-Suntay) and two illegitimate (including petitioner Emilio A.M. Suntay III), all descendants of her only child, the late Emilio A. Suntay. After Cristina’s death, Federico adopted the two illegitimate grandchildren. On October 26, 1995, Isabel filed a petition before the Regional Trial Court (RTC), Branch 78, Malolos, Bulacan (Special Proceeding Case No. 117-M-95), for letters of administration over Cristina’s estate. Federico opposed and nominated Emilio III to administer the estate. On November 9, 2001, the RTC appointed Emilio III as administrator. The Court of Appeals reversed that decision, appointed Isabel sole administratrix, and revoked Emilio III’s letters. On June 16, 2010, the Supreme Court in Suntay III v. Cojuangco-Suntay reversed the CA, diCase Digest (G.R. No. 183053)
Facts:
- Family and decedent background
- Cristina Aguinaldo-Suntay died intestate on June 4, 1990, survived by spouse Dr. Federico Suntay and five grandchildren: three legitimate (including respondent Isabel Cojuangco-Suntay) and two illegitimate (including petitioner Emilio A.M. Suntay III).
- Legitimate grandchildren lived with their mother after parental separation and a court-declared nullity of their parents’ marriage; illegitimate grandchildren were reared by Cristina and Federico and later adopted by Federico on September 27, 1993.
- Judicial proceedings
- On October 26, 1995, Isabel filed a petition for letters of administration over Cristina’s estate (SPC No. 117-M-95). Federico opposed, citing his preference as surviving spouse, incomplete heir enumeration, and superior capacity to administer; he nominated Emilio III as administrator. Emilio III intervened.
- The RTC, Branch 78, Malolos (Nov. 9, 2001) appointed Emilio III as sole administrator. The CA reversed, appointing Isabel. On June 16, 2010, the SC reversed the CA and ordered joint letters of administration to Isabel and Emilio III. Isabel filed a motion for reconsideration, resolved on October 10, 2012.
Issues:
- Who should be appointed administrator of Cristina’s estate—sole administratrix Isabel or co-administrators Isabel and Emilio III?
- Whether the statutory order of preference (Sec. 6, Rule 78, Rules of Court) can be set aside to justify joint administration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)