Case Summary (G.R. No. 124118)
Case Overview
- Parties Involved: Petitioners - Marino, Renato, Leticia, Imelda, Alicia, Ligaya, and Zenaida Adriano; Respondents - Court of Appeals, Celestina, Manolo, and Aida Adriano.
- Legal Context: Petition for review on certiorari regarding the Decision of the Court of Appeals affirming the Regional Trial Court's (RTC) dismissal of a civil case for annulment of will.
Background Facts
- Family Relations: Lucio Adriano had children from two marriages; three children with first wife Gliceria Dorado and eight with second partner Vicenta Villa.
- Marriage Events: Lucio married Gliceria on October 29, 1933, and they separated before Gliceria's death in 1968. Lucio married Vicenta on November 22, 1968.
- Will Execution: Lucio executed a last will on October 10, 1980, detailing property distribution among his children and wives.
Legal Proceedings
Probate and Opposition
- Probate Case: Celestina Adriano filed for probate of Lucio's will in RTC Lucena, which was allowed despite opposition from Vicenta.
- Civil Case for Annulment: Petitioners filed for annulment of Lucio's will, claiming properties were conjugal properties acquired during Lucio's cohabitation with Vicenta.
Court Findings
RTC Decision
- Dismissal of Annulment: The RTC found no grounds to nullify Lucio’s will, affirming that properties were acquired with conjugal funds from his first marriage.
- Property Evidence: Evidence presented indicated that properties in question were funded by Lucio's earnings during his marriage to Gliceria.
Appeal and Court of Appeals Ruling
- Affirmation of RTC: The Court of Appeals upheld the RTC's decision, ruling that the properties in question were conjugal properties of Lucio and Gliceria.
- Co-ownership Claim: Petitioners claimed co-ownership based on TCT No. T-56553 and a Deed of Sale from 1964. The court ruled these did not establish Vicenta's ownership due to Lucio's prior marriage.
Legal Principles Established
Co-Ownership in Civil Code
- Article 144: Addresses co-ownership principles for partners living together without marriage but requires that both parties must not be legally incapacitated to marry.
- Conjugal Property Presumption: Properties acquired during a valid marriage are presumed conjugal unless proven otherwise.
Key Rulings on Property Ownership
- Trust Doctrine: The court invoked the principle that property acquired during a marriage, even if titled in a common-law spouse's name, remains part of the conjugal property.
- Evidence Requirement: Petitioners failed to present substantial proof that Vicenta contributed to the acquisition of the contested properties.
Conclusion
- The decision of the RTC was upheld, affirming the testamentary provisions of Lucio Adriano's will.
- Petitioners’ claims were dismissed, emphasizing the binding nature of the trial court's factual findings and evidence regarding property ownership.
Key Takeaways
- No Grounds for Annulment: The court found no legitimate basis to annul Lucio's will.
- Conjugal Property: Properties were ruled as conjugal, belonging to Lucio and Gliceria, not Vicenta.
- Evidence Standards: The importan
Case Syllabus (G.R. No. 124118)
Case Overview
- This case concerns a petition for review on certiorari regarding the decision of the Court of Appeals.
- The focal point of the case is the validity of the last will and testament of Lucio Adriano, specifically concerning the disposition of his estate.
- The petitioners are the children of Lucio Adriano from his second marriage, while the respondents are his children from his first marriage.
Background Facts
- Lucio Adriano, also known as Ambrocio Adriano, was married to Gliceria Dorado on October 29, 1933, with whom he had three children: Celestina, Manolo, and Aida.
- The couple separated around 1942, and Gliceria passed away on June 11, 1968.
- Lucio then cohabited with Vicenta Villa, resulting in eight children, who are the petitioners in this case: Marino, Renato, Leticia, Imelda, Maria Alicia, Ligaya, Jose Vergel, and Zenaida (Jose Vergel predeceased the proceedings).
- Lucio married Vicenta on November 22, 1968, just five months after Gliceria's death.
- Lucio died on February 11, 1981, and his last will was executed on October 10, 1980.
Will and Estate Proceedings
- The will bequeathed properties, including a 45,000 square meter lot with a residential house and rice mill, among others, to both sets of children.
- Celestina, one of Lucio's children from his first marriage, was named the executrix of the will and filed for its probate in the RTC of Lucena City on February 18