Case Digest (G.R. No. 182740) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Testate Estate of Idonah Slade Perkins, the decedent Idonah Slade Perkins died in New York City on March 27, 1960, leaving, among other assets, two Philippine stock certificates covering 33,002 shares of Benguet Consolidated, Inc. The County Trust Company of New York was appointed domiciliary administrator of her estate but refused to surrender these certificates to the Philippine ancillary administration. On August 12, 1960, Prospero Sanidad initiated ancillary proceedings in the Court of First Instance of Manila; Lazaro A. Marquez was first appointed ancillary administrator and on January 22, 1963, he was replaced by Renato D. Tayag as ancillary administrator-appellee. On January 27, 1964, the trial court ordered the County Trust Company to “produce and deposit” the certificates with the ancillary administrator, but the order went unheeded. Thereupon, on February 11, 1964, Tayag petitioned to have the certificates “declared or considered as lost.” On May 18, 1964, the lower Case Digest (G.R. No. 182740) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Idonah Slade Perkins, a U.S. domiciliaria, died testate on March 27, 1960 in New York City, owning two stock certificates covering 33,002 shares of Benguet Consolidated, Inc.
- County Trust Company of New York served as domiciliary administrator; Prospero Sanidad opened ancillary proceedings in Manila on August 12, 1960, succeeded by Lazaro A. Marquez, then by Renato D. Tayag on January 22, 1963.
- Proceedings Below
- On January 27, 1964, the Manila CFI ordered the County Trust Company to produce and deposit the Philippine stock certificates with the ancillary administrator or the Clerk of Court; the order went unheeded.
- On February 11, 1964, the ancillary administrator petitioned the court to declare the certificates “considered as lost” to permit issuance of duplicates.
- On May 18, 1964, the CFI ordered:
- The original certificates be deemed lost for purposes of the Philippine estate.
- Cancellation of the existing certificates.
- Benguet Consolidated, Inc. to issue new certificates and deliver them to the ancillary administrator or the Probate Division.
- Appeal
- Benguet Consolidated, Inc. (Philippine corporation) appealed, contending the certificates physically exist in New York and its by-laws require a final court determination on ownership before reissuance.
- The domiciliary administrator did not appeal; the corporation alleged “it is immaterial” who holds the certificates but opposed the fiction of loss and non-compliance with by-laws.
Issues:
- Ancillary Administrator’s Authority
- Does the ancillary administrator have power over decedent’s assets located in the Philippines?
- Can the court compel issuance of replacement certificates under that power?
- Stock Certificates and Legal Fiction
- May the court treat existing certificates held abroad as “lost” to enforce its decree?
- Are legal fictions permissible to counter willful non-compliance?
- Corporate By-laws vs. Court Decree
- Do Benguet Consolidated’s by-laws governing lost or destroyed certificates override a valid judicial order?
- Can corporate by-laws suspend issuance of new certificates pending final court resolution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)