Case Summary (G.R. No. 148208)
Background of the Case
This legal action was initiated on February 15, 1913, with the primary aim of declaring certain properties escheated to the City of Manila. The properties in question, comprising five parcels of land located in the districts of Malate and Paco, were linked to Ana Sarmiento, who reportedly had no heirs at the time of her death in 1668.
Findings from the Trial
After a thorough presentation of evidence, the trial court, presided over by Judge A. S. Cross-field, concluded that the petitioner’s request for escheatment should be denied. Subsequent to this ruling, the petitioner appealed, asserting several errors in the lower court’s judgment. The appellate court, upon reviewing the record, established several critical facts regarding Ana Sarmiento’s last will and testament.
Legal Determinations Concerning the Will
The evidence presented indicated that Ana Sarmiento executed a will on November 17, 1668, and later amended this will with a codicil on November 23, 1668. Furthermore, she created another will on May 19, 1669, which reaffirmed the previous codicil. Importantly, her will included specific provisions for the establishment of a "Capellania de Misas," assigning her nephew, Pedro del Castillo, as the first chaplain. The continuous and perpetual administration of the property was clearly articulated within her will.
Legal Framework for Escheatment
Section 750 of Act No. 190 outlines the conditions under which property may be declared escheated, specifically in cases of intestacy when an individual dies without heirs. However, the evidence corroborated that Ana Sarmiento did not die intestate. She explicitly left a will appointing her nephew as administrator, which serves as a legitimate indication of a designated heir for the property in question.
Conclusion on Property Administration
The appellate court determined that the Roman Catholic Archbishop of Manila had rightfully maintained possession and administration of
...continue readingCase Syllabus (G.R. No. 148208)
Case Background
- The case was initiated in the Court of First Instance of the City of Manila on February 15, 1913.
- The primary aim was to declare certain properties as escheated to the City of Manila.
- The contested properties included five parcels of land located in the districts of Malate and Paco, as per the plan documented in the Department of Engineering and Public Works of Manila (Plan No. B-10-27).
- The City of Manila claimed ownership based on the premise that Ana Sarmiento, the original owner, died in 1668 without any heirs or persons entitled to inherit her estate.
Trial Court Proceedings
- The trial was overseen by the Honorable A. S. Cross-field, who meticulously evaluated the evidence presented.
- The court ultimately denied the City of Manila's petition without a determination of costs.
- Following the denial, the City of Manila appealed, citing several alleged errors in the trial court's judgment.
Evidence and Findings
- Substantial evidence indicated that Ana Sarmiento resided in Manila with her husband prior to November 17, 1668.
- On November 17, 1668, she execute