G.R. No. 116835 - Vda. de Chua vs. Court of Appeals

Roberto Lim Chua lived with Florita A. Vallejo from 1970 to 1981 without marriage.
The couple had two illegitimate children: Roberto Rafson Alonzo (born April 28, 1977) and Rudyard Pride Alonzo (born August 30, 1978).

Roberto Lim Chua died intestate on May 28, 1992, in Davao City.
On July 2, 1992, Florita A. Vallejo filed a petition before the Regional Trial Court (RTC) of Cotabato City titled “Petition for Declaration of Heirship, Guardianship Over the Persons and Properties of Minors Roberto Rafson Alonzo and Rudyard Pride Alonzo, all surnamed Chua and Issuance of Letters of Administration.”
The petition averred:

The two minors resided with Vallejo in Cotabato City.
Decedent left an estate valued at P5,000,000 consisting of various real properties, residential houses, vehicles, and stockholdings.
Decedent died single, leaving no legitimate descendants or ascendants, thereby making the two minors his sole heirs under Article 988 of the Civil Code.
Vallejo sought appointment as guardian of the minors and asked for letters of administration over the estate.

On July 21, 1992, Antoinetta Garcia Vda. de Chua, alleging to be the surviving spouse, filed a motion to dismiss for improper venue, contending that Davao City was the proper forum since it was the decedent’s residence at death.
Vallejo opposed, asserting the minors’ residence in Cotabato City as the basis for proper venue under Rule 92, Section 1 of the Rules of Court, and denied Garcia’s spousal status, claiming decedent died a bachelor.
Vallejo later filed a motion to admit an amended petition renaming the case to include “Settlement of the Intestate Estate” but containing materially identical allegations.

On August 21, 1992, the trial court denied Garcia’s motion to dismiss for lack of merit, ruling:

Garcia failed to prove her marriage to the decedent in light of absence of a valid marriage contract and supporting records.
Decedent’s actual residence was Cotabato City despite business ties to Davao City.
Venue was proper in Cotabato City due to minors’ residence and prior assumption of jurisdiction by the RTC of Cotabato.

On August 31, 1992, the court appointed Romulo Lim Uy as special administrator of the estate and Florita Vallejo as guardian of the minors.
Subsequent motions by Garcia to recall letters of administration and to declare the proceedings a mistrial were denied by the trial court in November and December 1993.

Garcia filed a petition for certiorari and prohibition before the Court of Appeals (CA-G.R. Sp. No. 33101), alleging:

The trial court unilaterally converted guardianship proceedings into intestate estate proceedings.
The trial court acted without jurisdiction and without notice to her.
She was deprived of due process.
Remedy should be appeal, not certiorari.

The Court of Appeals affirmed the trial court decision, holding that the original petition clearly included both guardianship and administration of the estate, thus no new publication of the amended petition was necessary.
The appellate court further held that Garcia was not a party with standing to oppose the petition, having failed to prove spousal status.
The appropriate remedy for Garcia was appeal, not certiorari or prohibition.

Antoinetta Garcia filed a petition before the Supreme Court, contesting the findings of the Court of Appeals on several grounds, including lack of jurisdiction of the trial court to hear intestate estate issues in the guardianship proceeding, lack of publication of the amended petition, denial of due process due to ex-parte orders, and inappropriate remedy sought.

Whether the original petition filed by Vallejo was a petition exclusively for guardianship or also included administration of the intestate estate of Roberto Lim Chua.

Whether the amended petition, which included settlement of the intestate estate, required a new publication of notice for hearing.

Whether Antoinetta Garcia, not proven to be the lawful surviving spouse, had legal personality or standing to file a motion to dismiss or to participate in the intestate estate proceedings.

Whether the trial court committed grave abuse of discretion in issuing ex-parte orders without notice to Garcia, thereby depriving her of due process.

Whether certiorari was the proper remedy for Garcia instead of an ordinary appeal.