Case Summary (G.R. No. 253426)
Factual Background and Proceedings Before the RTC
Petitioner filed for probate of the Last Will and Testament of the decedent in 2003, seeking allowance of the will and her appointment as executor. The will designated her as executor and largely disinherited most grandchildren, except Gregorio Constantino E. Manguerra, who was bequeathed specific properties and cash. The will detailed specific bequests to various heirs and residual estate distribution to petitioner.
The RTC initially allowed the will but invalidated the disinheritance clause, allowing the respondents their legitime as compulsory heirs in representation of their deceased father. The RTC subsequently granted partial distribution orders for uncontested portions of the estate and later a final distribution order for the remainder, which included reverting properties to the estate due to non-acceptance by Gregorio.
The respondents filed appeals against these distribution orders. The RTC disapproved the late filing of respondents’ record on appeal regarding the final distribution order, holding that the proper remedy was an ordinary appeal filed within 15 days. Respondents sought relief from the CA claiming grave abuse of discretion by the RTC in disapproving their appeal filings.
Petitioners’ Arguments and CA Ruling
Petitioner contended that where a special proceeding has been fully resolved, appeals should be by ordinary appeal with a 15-day period and no record on appeal is necessary. Petitioner argued that the CA erred in ruling that both a notice of appeal and a record on appeal were required, and that the filing period remained 30 days.
The CA ruled that the proper mode of appeal from judgments or final orders in special proceedings is a notice of appeal and a record on appeal as mandated by Section 2(a) of Rule 41 of the Rules of Court. Since Section 3 provides a 30-day period for filing when a record on appeal is required, the RTC gravely abused its discretion by dismissing respondents’ appeal for tardiness. The CA ordered the RTC to approve the respondents’ notice of appeal and record on appeal and remove the final distribution order from the book of entries of judgment.
Issue Before the Supreme Court
The principal issue was whether a record on appeal remains necessary in special proceedings when the trial court has completely disposed of the case, or whether an ordinary appeal by notice alone suffices with a reduced 15-day period.
Supreme Court’s Analysis on the Mode and Period of Appeal in Special Proceedings
- Special proceedings may involve multiple appeals because various material issues may be determined at different stages (per Section 1, Rule 109 of the Rules of Court and doctrinal precedents).
- Section 2(a), Rule 41 of the Rules of Court explicitly requires both a notice of appeal and a record on appeal in special proceedings or cases with multiple appeals.
- Section 3, Rule 41 sets the reglementary period for filing a notice of appeal and record on appeal as 30 days from notice of the judgment or final order.
- The Supreme Court explained that the purpose of the record on appeal is to allow the lower court to retain the original records and continue with remaining proceedings unaffected by the appeal, while the appellate court gains full access to relevant records.
- The Court distinguished the present case from Republic v. Nishina, where the Court held a record on appeal was unnecessary because the petition involved cancellation of birth records and change of surname, and no other matter remained before the trial court.
- The present case involves probate and distribution in estate settlement, a special proceeding with multiple stages and unresolved matters potentially remaining (e.g., enforcement of shares, advance distribution). Thus, Nishina is not controlling.
- The Court stressed that the Rules of Court do not limit the necessity of a record on appeal based on whether a case is fully disposed of and that the 30-day period still governs appeals requiring both notice and record on appeal.
- The Supreme Court affirmed the CA’s ruling that the RTC committed grave abuse of discretion when it disapproved respondents’ timely filed notice and record on appeal.
Continuing Jurisdiction and Multiple Appeals in Estate Proceedings
- The Supreme Court noted that even after a final distribution order, there may be pending issues for the trial court, such as advance distribution of unaffected estate portions or enforcement of shares, justifying retention of records and the necessity of a record on appeal.
- Section 2, Rule 109 of the Rules of Court permits advance distribution notwithstanding pending controversies or appeals in estate proceedings, which requires the RTC to retain jurisdiction and records.
- Respondents have legal remedies to enforce their rights if distribution is delayed or non-existent, which also supports ongoing judicial involvement.
Conclusion and Disposition
The Supreme Court denied petitioner’s petition for review, affirming the CA’s decision and resolution that upheld the respondents’ mode and timeliness of appeal. The Court underscored that the proper mode of appeal in special proceedings involving multiple appeals is by notice of appeal and record on appeal within 30 days, regardless of claims that the case was fully disposed of. The RTC’s disapproval of respondents’ appeal for being filed out of time was unwarranted.
Summary of Legal Principles and Procedural Rules
- Special Proceedings and Multiple Appeals: Special proceedings, including probate and estate distribution, may give rise to multiple final orders
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Case Syllabus (G.R. No. 253426)
Case Background and Factual Antecedents
- Petitioner Ana Maria C. Manguerra filed a petition for the probate of the Last Will and Testament of Concepcion A. Cuenco Vda. De Manguerra before the RTC of Makati City on January 27, 2003.
- The decedent’s will named petitioner as the executor and disinherited all but one grandchild (Gregorio Constantino E. Manguerra) from inheritance.
- The will detailed the distribution of specific properties and cash legacies among the devisees, including real estate in Cebu City, Manila, and Makati City.
- The disinheritance clause was challenged by respondents, who are grandchildren of the decedent.
- On April 15, 2003, the RTC allowed the probating of the will but invalidated the disinheritance provision, declaring it invalid for not aligning with causes of disinheritance under Philippine law.
- The RTC initially issued letters testamentary to petitioner for estate administration, with limited authority to dispose of estate assets.
- Upon partial reconsideration, the RTC declared that the issue of disinheritance was premature at the stage of allowance of the will and could be determined in further proceedings.
- Petitioner filed motions for distribution of estate properties, resulting in a Partial Distribution Order in 2013 distributing uncontested portions of the estate.
- Respondents opposed the Partial Distribution Order, filing motions for reconsideration and appealing via notice and record on appeal.
- In 2014, while respondents’ appeal was pending, petitioner filed a motion for the Final Distribution of the remainder of the estate, which the RTC granted in a Final Distribution Order.
- The Final Distribution Order directed distribution of residual estate assets and repossession of Gregorio’s unaccepted legacy back to the estate.
- Respondents filed a notice of appeal and record on appeal from the Final Distribution Order, but the RTC disapproved the appeal as untimely.
- Respondents filed a Petition for Certiorari with the Court of Appeals (CA) contesting the RTC’s orders disapproving their appeal.
Procedural History
- The RTC issued orders on April 5, 2017, and June 16, 2017, disapproving respondents’ notice of appeal and record on appeal from the Final Distribution Order for being filed beyond the 15-day reglementary period for ordinary appeal.
- The RTC also granted petitioner’s motion for Entry of Judgment, effectively finalizing the Final Distribution Order.
- Respondents elevated the matter to the CA via Petition for Certiorari, alleging grave abuse of discretion by the RTC.
- On June 17, 2019, the CA reversed and set aside the RTC’s orders, directing the RTC to approve respondents’ notice of appeal and record on appeal, acknowledging the timeliness of filing within the 30-day period prescribed for appeals involving record on appeal.
- Petitioner moved for reconsideration before the CA, which was denied on September 8, 2020.
- Aggrieved, petitioner filed the instant Petition for Review on Certiorari before the Supreme Court, contesting the CA’s ruling on the mode and period of appeal in special proceedings.
Issues Presented for Resolution
- Whether in special proceedings fully disposed of by the trial court, a record on appeal is still necessary alongside a notice of appeal.
- Whether the reglementary period for filing an appeal in special proceedings where the case is fully disposed of is 15 days for notice of appeal only, or 30 days requiring both notice and record on appeal.
- Whether the RTC committed grave abuse of discretion in disapproving respondents’ appeal for being filed out of time.
Supreme Court’s Legal Analysis and Ruling
- The Court reaffirmed that mult