Case Digest (G.R. No. 155733)
Facts:
In the Matter of the Intestate Estates of the Deceased Josefa Delgado and Guillermo Rustia, G.R. No. 155733, January 27, 2006, the Supreme Court Second Division, Corona, J., writing for the Court. Petitioners sought reinstatement of the May 11, 1990 decision of the Regional Trial Court (RTC) of Manila, Branch 55, in SP No. 97668, which the Court of Appeals reversed in its October 24, 2002 decision.The dispute concerns competing claims to the intestate estates of Josefa Delgado and Guillermo Rustia. Petitioners are relatives and collateral heirs of Josefa Delgado led by Carlota Delgado vda. de de la Rosa (substituting Luisa Delgado vda. de Danao); respondents are the sisters and collateral relatives of Guillermo Rustia (the oppositors in the RTC appeal) and intervenor Guillerma Rustia (an alleged illegitimate daughter of Guillermo). The litigation asks who are the lawful heirs of the two decedents and who should be appointed administrators.
Factually, key contentions were: (1) whether Josefa’s mother Felisa Delgado ever married Ramon Osorio—because if they were married, Luis Delgado would be a legitimate half-brother of Josefa and excluded from reciprocal succession under Art. 992 of the New Civil Code; (2) whether Josefa and Guillermo were validly married, since cohabitation for over 50 years was admitted but no marriage record was produced; (3) whether intervenor Guillerma and the ampun-ampunan child Guillermina were lawful heirs (recognition/adoption issues); and (4) the validity of Guillermo’s June 15, 1973 affidavit of self-adjudication.
Procedural history: On May 8, 1975 Luisa Delgado filed the original petition for letters of administration in RTC Manila, Branch 55; oppositors (Guillermo’s sisters and other kin) opposed. Guillerma moved to intervene in November 1975 and was allowed. The petition was amended April 3, 1978 to allege the spouses had never actually married. After various motions, the RTC on May 11, 1990 declared petitioners the only legal heirs of Josefa and declared intervenor Guillerma the sole heir of Guillermo, set aside Guillermo’s affidavit of self-adjudication, and appointed Carlota as administratrix.
Oppositors appealed but initially the appeal was dismissed for late filing of the record on appeal (Sept. 25, 1990); a certiorari/mandamus to the Court of Appeals was dismissed but later, upon motion for reconsideration, the Court of Appeals allowed the record (Nov. 27, 1991). This Court earlier, in De la Rosa v. Court of Appeals (345 Phil. 678 (1997)), allowed continuance of the appeal on grounds of substantial justice. The Court of Appeals, acting on the appeal, reversed the RTC in a decision rendered (amended) October 24, 2002, declaring the spouses validly married, denying Guillerma inheritance from Guillermo, revoking her appointment as administratrix, and remanding the self-adjudication issue to the trial court.
...(Pro-only)Issues:
- Was there a valid marriage between Guillermo Rustia and Josefa Delgado?
- Who are the lawful heirs of Josefa Delgado and Guillermo Rustia?
- Who should be issued letters of administration for the unsettl...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)