Title
Araujo vs. Celis
Case
G.R. No. 2308
Decision Date
Aug 3, 1910
Rosario’s will, authenticated by an unauthorized gobernadorcillo near Pototan, was ruled invalid; her heirs, not her husband’s estate, inherited the hacienda Pangpang.
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Case Summary (G.R. No. 2308)

Case Background

  • The case involves a legal dispute between plaintiffs Nieves Araujo et al. and defendant Gregoria Celis regarding the inheritance of the hacienda known as Pangpang, originally owned by Rosario Darwin Araujo.
  • Rosario Darwin inherited the hacienda from her mother, Asuncion Araujo y Belen, married Jose Araujo y Celis, and died on January 22, 1888, leaving no direct descendants.

Inheritance Claim

  • Legal Principle: The plaintiffs claim to be the nearest collateral relatives of Rosario and seek to inherit her estate.
  • Key Definitions:
    • Collateral Relatives: Individuals related to the deceased through siblings or other non-direct lines.
  • Requirements:
    • Proof of relationship to the deceased.
    • Legal claim to the estate based on intestacy laws if no valid will exists.

Defendant's Position

  • Claim of Will: The defendant asserts that Rosario left a will bequeathing her property to her husband, Jose Araujo. Upon his death, she claims to have inherited his property under the law.
  • Legal Validity of Will: The decisive issue is whether the will was executed legally and validly.

Execution of the Will

  • Judgment Findings: The trial judge found that the will was signed by eight witnesses, including Nieves Araujo, and that Rosario's signature was written at her request due to her illness.
  • Key Procedures:
    • The will was executed before the gobernadorcillo of Barotac Nuevo rather than a notary public, raising questions of its legality.
    • For a will to be valid without a notary, specific formalities must be adhered to as per the laws in force at the time.

Legal Authority of Gobernadorcillo

  • Legal Restriction: The gobernadorcillo was not authorized to legalize the will as Barotac Nuevo is less than two leguas from Pototan, where a notary resided.
  • Cross-References:
    • Law provisions from Novisima Recopilacion detailing who can execute and legalize wills.
    • Prohibition against gobernadorcillos legalizing public instruments within a distance of 2 leguas from their judicial seats.

Nullity of the Will

  • Consequences: The lack of proper legalization renders the will null and void as a public document. Consequently, it is also invalid as a private document since it was not properly attested.
  • Legal Implications:
    • The plaintiffs are entitled to inherit the hacienda as there is no valid will to contest their claim.

Restitution of Property

  • Possession: The defendant entered possession of the property under the assumption of a valid title derived from the will.
  • Legal Duty: Upon being summoned to trial, the defendant must return the property and any fruits collected from it after the summons.
  • Timeframe: The restitution of fruits will be calculated from the date of the defendant's answer to the complaint.

Key Takeaways

  • The case underscores the critical importance of adhering to legal formalities in will execution.
  • The governor's
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