Case Summary (G.R. No. 251350)
Background and Relevant Events
Federico and Cristina had a son, Emilio, who predeceased them. Federico subsequently adopted respondents Emilio III and Nenita, who cared for him in his old age. After Cristina's death in 1990, petitioners alleged that Federico improperly disposed of Cristina’s properties. In response, Isabel filed a Petition for the Issuance of Letters of Administration, claiming that Federico was unfit to manage the estate.
In response to these actions, Federico executed his First Will on April 21, 1997, which acknowledged the petitioners as legitimate heirs. However, after withdrawing this document, and in light of a subsequent judicial declaration of the nullity of Emilio’s marriage to their mother, he argued that the petitioners were illegitimate and thus disqualified from inheriting.
Lower Court Proceedings
Federico filed a second Last Will and Testament on March 20, 1999, where he again attempted to disinherit the petitioners based on allegations of maltreatment. The Regional Trial Court (RTC) admitted this Second Will to probate after an unopposed hearing, asserting that Federico had testamentary capacity despite being of advanced age. The petitioners, ignorant of these proceedings, contested the RTC's decisions after discovering that they had been disinherited.
Grounds for Annulment of Judgment
Petitioners subsequently filed a Petition for Annulment of Judgment with the Court of Appeals (CA), claiming they were not notified of the probate proceedings. The crux of their argument was rooted in allegations of extrinsic fraud, with assertions that Federico's actions were aimed at concealing the probate proceedings from them.
The CA denied their petition, finding no merit in the petitioners' claims of lack of notification, and stated that the RTC's service of processes enjoys a presumption of regularity.
Supreme Court's Ruling
Upon review, the Supreme Court granted the petition for annulment. The Court reiterated that a petition for annulment of judgment serves as a remedy in instances where ordinary remedies have been exhausted or are not applicable, solidifying the grounds for annulment as either extrinsic fraud, lack of jurisdiction, or violation of due process.
Findings on Extrinsic Fraud
The Court underscored that Federico’s failure to provide the petitioners' addresses constituted a significant oversight, as it prevented the RTC from notifying petitioners of proceedings that directly
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Case Overview
- This case involves a petition for review on certiorari by petitioners Isabel Cojuangco-Suntay and Emilio Cojuangco-Asuntay, Jr. against respondents Emilio A.M. Suntay III and Nenita TaAedo.
- The petition contests the Decision dated June 30, 2017, and the Resolution dated January 7, 2020, of the Court of Appeals (CA) in CA-G.R. SP No. 97052.
- The CA denied the Petition for Annulment of Judgment filed by the petitioners and upheld the earlier decisions of the Regional Trial Court (RTC) of La Trinidad, Benguet.
Background of the Case
- The case centers on the probate proceedings of the Last Will and Testament of Federico C. Suntay, who was married to Cristina Aguinaldo-Suntay and had a child, Emilio.
- Emilio predeceased both parents and was married to Isabel, with whom he had three children, including petitioners Emilio Jr. and Isabel.
- Following Cristina's death intestate in 1990, petitioners alleged that Federico began illegally disposing of her properties, prompting Isabel to file for Letters of Administration in 1995.
The First Will and Subsequent Developments
- Federico executed his First Will on April 21, 1997, which acknowledged petitioners as legitimate heirs entitled to inherit.
- However, he later withdrew his First Probate Petition, claiming he had revoked his First Will.
- In 1997, Federico began to deny Isabel and her children’s legitimacy, asserting they were illegitimate due to the annulment of Emilio's marriage.
The Second Will
- Following a Su