Case Digest (G.R. No. 232579)
Facts:
Dr. Nixon L. Treyes v. Antonio L. Larlar, et al., G.R. No. 232579, September 08, 2020, Supreme Court En Banc, Caguioa, J., writing for the Court.Petitioner Dr. Nixon L. Treyes (petitioner Treyes) was married to Rosie Larlar Treyes (Rosie), who died intestate on May 1, 2008, leaving no children and seven siblings — respondents Antonio L. Larlar, Rev. Fr. Emilio L. Larlar, Heddy L. Larlar, Rene L. Larlar, Celeste L. Larlar, Judy L. Larlar, and Yvonne L. Larlar (collectively, the private respondents). At the time of Rosie's death she and petitioner allegedly owned fourteen real properties as conjugal property. The private respondents relied on Article 1001 and Article 777 of the Civil Code to assert successional rights that vested at Rosie's death.
Petitioner executed two Affidavits of Self-Adjudication (dated September 2, 2008 and May 19, 2011) and had new Transfer Certificates of Title (TCTs) issued in his name in 2011. The private respondents wrote petitioner in February and April 2012 requesting settlement of Rosie's estate; when ignored, they discovered the new titles and, on July 12, 2013, filed before the Regional Trial Court (RTC) of San Carlos City, Branch 59 a Complaint for annulment of the Affidavits of Self-Adjudication, cancellation of TCTs, reconveyance of ownership and possession, partition, and damages (Civil Case No. RTC‑1226), attaching birth certificates to prove filiation.
Petitioner initially filed a special appearance and motion to dismiss for lack of personal jurisdiction; after re-service of summons he filed a second Motion to Dismiss (June 20, 2014) asserting improper venue, prescription, and lack of subject‑matter jurisdiction. In a Resolution dated July 15, 2014 the RTC denied the motion but held it lacked jurisdiction over the partition cause of action and ordered that cause dropped; the RTC later denied reconsideration in an Order dated August 27, 2014. The private respondents’ core reliefs sought annulment of the affidavits, reconveyance to the estate, partition, and damages.
Petitioner moved to the Court of Appeals (CA) via a Rule 65 certiorari petition challenging the RTC’s denial of his motion to dismiss; the CA (Nineteenth Division) denied relief in a Decision dated August 18, 2016 (affirming the RTC’s July 15 and August 27, 2014 issuances) and denied reconsideration in a Resolution dated June 1, 2017. Petitioner then f...(Pro-only)
Issues:
- Did the RTC commit grave abuse of discretion in denying petitioner Treyes’ second Motion to Dismiss on the ground of improper venue?
- Did the RTC commit grave abuse of discretion in denying the motion on the ground of prescription?
- Did the RTC commit grave abuse of discretion in denying the motion for lack of jurisdiction over the subject matter because the private respondents had not first obtained a judicial declaratio...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
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