Case Digest (G.R. No. 206528) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lauro G. Vizconde v. Court of Appeals, petitioner Lauro G. Vizconde was the husband of the late Estrellita Nicolas-Vizconde, who in May 1979 purchased a 10,110-sq.m. parcel in Valenzuela, Bulacan from her father, Rafael Nicolas, for ₱135,000.00. Title No. V-554 was issued to Estrellita. On March 30, 1990, she sold this Valenzuela property for ₱3,405,612.00 and used part of the proceeds to acquire a lot with improvements in BF Homes, Parañaque (“Parañaque property”). On June 30, 1991, Estrellita and her two daughters were tragically murdered, and petitioner succeeded to their interests. An extra-judicial settlement divided the Parañaque property, a car, and bank deposits between petitioner and Rafael and Salud Nicolas, waiving all claims. Rafael died on November 18, 1992, and an intestate estate proceeding (Sp. Proc. No. C-1679) was filed by Teresita Nicolas-de Leon before RTC Branch 120, Caloocan City, listing Salud, Ramon, Ricardo (incompetent), and Antonio’s surviving famil Case Digest (G.R. No. 206528) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Family Relations
- Lauro G. Vizconde (petitioner) married Estrellita Nicolas-Vizconde, daughter of Rafael and Salud Gonzales-Nicolas.
- Estrellita and Lauro had two daughters, Carmela and Jennifer.
- Property Transactions
- May 22, 1979: Estrellita bought a 10,110-sqm lot in Valenzuela, Bulacan from her father Rafael for ₱135,000; TCT No. V-554 issued.
- March 30, 1990: Estrellita sold the Valenzuela property to Amelia Lim and Maria Natividad Balictar Chiu for ₱3,405,612.
- June 1990: With part of the sale proceeds, Estrellita acquired a Parañaque property with improvements from Premiere Homes, Inc.; purchased a car and deposited the balance in bank accounts.
- Deaths and Extra-Judicial Settlement
- June 30, 1991: Estrellita and her two daughters were murdered (Vizconde Massacre); NBI found Estrellita died first.
- Petitioner and his daughters succeeded to Estrellita’s estate; upon the subsequent death of both daughters, petitioner became sole heir.
- Petitioner, Rafael, and Salud executed an Extra-Judicial Settlement: bank deposits (net ₱3,000,000) split 50/50 between petitioner and Rafael; Parañaque property and car awarded entirely to petitioner; Rafael and Salud waived claims.
- Intestate Proceedings of Rafael’s Estate
- November 18, 1992: Rafael died; Sp. Proc. No. C-1679 filed in RTC Caloocan, naming Salud, Ramon, Ricardo, and Antonio’s family as heirs; Teresita de Leon sought appointment as Special Administratrix and guardian ad litem.
- Ramon Nicolas opposed and later filed Sp. Proc. No. C-1699 to be guardian and to compel collation of properties received by Estrellita, including the Valenzuela and Parañaque properties.
- November 9, 1993: RTC appointed Ramon guardian and Teresita as Special Administratrix; omitted petitioner and the Parañaque property from the estate.
- January 5, 1994: RTC removed Ramon as guardian for unauthorized sale of ward’s property.
- March 10, 1994: RTC granted Ramon’s motion to include petitioner in intestate proceedings and to collate the Parañaque property, car, and remaining proceeds.
- August 12, 1994: RTC denied petitioner’s motion for reconsideration, ruling the Valenzuela transfer was gratuitous and the Parañaque property subject to collation.
- December 14, 1994: Court of Appeals denied petitioner’s certiorari petition.
- December 4, 1995: Supreme Court gave due course to petitioner’s petition for review on certiorari.
Issues:
- May petitioner, a son-in-law, be included as a compulsory heir in Rafael’s intestate estate?
- Can the probate court validly determine the title and consideration of the Valenzuela property transfer?
- Is the Parañaque property subject to collation in Rafael’s estate?
- Can proceeds of the Valenzuela property be collated when Estrellita predeceased Rafael and those proceeds were distributed?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)