Case Summary (G.R. No. 169700)
Procedural Background
The case involves a petition for review on certiorari challenging the June 17, 2005 Decision of the Court of Appeals in CA-G.R. CV No. 53929, which modified the RTC's earlier ruling regarding the probate of the decedent’s will. The case arose following the death of Moises F. Banayad, for whom Apolonia Banayad Frianela filed a petition for the allowance of his holographic will dated November 18, 1985. This petition was opposed by Servillano Banayad, Jr., who sought to have two later wills of the decedent, dated September 27 and 28, 1989, recognized.
Trial Court Decision
The RTC ruled in favor of the respondent, determining that the September 27, 1989 will revoked the earlier will and appointed the respondent as administrator of the estate. Following the RTC's ruling, the petitioner appealed to the Court of Appeals.
Court of Appeals Ruling
The Court of Appeals modified the RTC's decision, stating that the September 27, 1989 will only revoked the November 18, 1985 will concerning the real property of the estate and allowed both wills to coexist in terms of personal property. The appellate court also denied a subsequent motion for partial reconsideration filed by the petitioner.
Jurisdictional Issues
Upon review, the Supreme Court identified a critical jurisdictional issue that had not been addressed in earlier proceedings. The RTC lacked jurisdiction over the probate case due to the failure of the petitioner to include an averment of the gross value of the estate in the original petition. This oversight is significant because jurisdiction is determined by the law at the time of the case initiation, which necessitates specific allegations concerning the gross value of the estate for a Regional Trial Court to have jurisdiction.
Governing Legal Provisions
According to Batas Pambansa (B.P.) Blg. 129, specifically Sections 19 and 33:
- The RTC can exercise exclusive original jurisdiction over probate matters where the gross value of the estate exceeds twenty thousand pesos (₱20,000.00).
- Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts have jurisdiction over matters where the demand does not exceed ₱20,000.00.
The evidence presented indicated that the original petition did not specify the gross value of Moises Banayad’s estate, thereby rendering it impossible to determine the appropriate jurisdiction for the case.
Consequences of Lack of Jurisdiction
The Supreme Court concluded that the RTC, having incorrectly assumed jurisdiction, rendered all proceedings and decisions that ensued null and void. Importantly, the doctrine of estoppel by laches, which might typic
...continue readingCase Syllabus (G.R. No. 169700)
Case Background
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court.
- The petition challenges the June 17, 2005 Decision of the Court of Appeals (CA) in CA-G.R. CV No. 53929, along with the August 17, 2005 Resolution denying the motion for partial reconsideration.
- After the death of the testator Moises F. Banayad, the petitioner, Apolonia Banayad Frianela, filed a petition for the allowance of his holographic will dated November 18, 1985, on June 3, 1991.
Parties Involved
- Petitioner: Apolonia Banayad Frianela, named as a devisee in Moises's will.
- Respondent: Servillano Banayad, Jr., a cousin of the petitioner, who opposed the petition and counter-petitioned for the allowance of two other holographic wills dated September 27 and 28, 1989.
Initial Proceedings
- The Regional Trial Court (RTC) of Pasay City rendered a Decision on September 29, 1995, allowing the September 27, 1989 will and appointing the respondent as the administrator of Moises's estate.
- The RTC ruled that the September 27, 1989 holographic will revoked the November 18, 1985 will.
Court of Appeals Decision
- The Court of Appeals modified the RTC's decision, rul