Case Summary (G.R. No. 147148)
Key Dates
July 8, 1996 — respondent filed the petition for letters of guardianship.
August 15, 1996 — petitioner filed an amended Opposition.
October 4, 1996 — RTC issued Decision finding Julieta incompetent and appointed respondent guardian; bond set at P200,000.
November 4, 1996 — RTC denied petitioner’s Motion for Reconsideration.
June 19, 2000 — Court of Appeals affirmed the RTC decision.
Petition for review filed to the Supreme Court; Supreme Court decision issued January 13, 2003.
Applicable constitutional framework: 1987 Philippine Constitution (decision date post‑1990).
Applicable Law and Precedents
Primary procedural constraint invoked: Rule 45 of the Rules of Court (review by certiorari to the Supreme Court is confined to questions of law). The appeals court and Supreme Court repeatedly applied the well‑established principle that findings of fact by trial courts (and the CA’s assessment of evidence) are generally accorded great weight and will not be disturbed on certiorari except under recognized exceptions (e.g., findings based on speculation, manifestly mistaken inferences, grave abuse of discretion, misapprehension or conflict of facts, conclusions unsupported by citation of specific evidence). Precedents cited include Perez v. Court of Appeals, Chan Sui Bi, China Road and Bridge Corporation, Feliciano v. Camahort, and Garchitorena v. Sotelo.
Petition for Letters of Guardianship — Factual Allegations
Respondent alleged that Julieta had been hospitalized and medically attended for old age, general debility, and strokes (one occurring in early 1995 in the United States), that Julieta was bedridden and dependent on assistance (wheelchair), and that Julieta owned properties with an aggregate estimated value of P1,000,000. Respondent asserted that Julieta could not manage herself or her business interests and needed a guardian to assist in ongoing corporate and agricultural enterprises. The petition noted consent to the petition from Julieta’s nearest kin (her sisters).
Opposition and Amended Opposition by Petitioner
Petitioner opposed the guardianship on grounds that Julieta was competent and sane and that there was no need for a guardian; petitioner attached letters purportedly written by Julieta to demonstrate capability. Petitioner argued that respondent was unfit because their interests were antagonistic, cited precedent for disqualifying guardians with conflicting interests, and alternatively proposed other individuals who might be appointed guardian.
RTC Decision and Rationale
The trial court found Julieta incompetent and incapable of managing herself and her property (citing senility and avascular dementia). The RTC appointed respondent Amparo as guardian over Julieta’s person and properties, concluding that Amparo — as a sister with business management experience and family involvement — was best suited to take care of Julieta’s concerns and wellbeing. The RTC noted the advanced age of petitioner (90) as a factor weighing against her capacity to perform the duties of guardian, and also observed that petitioner’s suggestion of hostility or dislike by Amparo did not, without more, render Amparo unsuitable. The court further remarked that petitioner had not objected among the nearest kin and that petitioner’s allegations as to transfers of shares might indicate adversarial interest on petitioner’s part.
RTC Order on Motion for Reconsideration
The RTC denied petitioner’s Motion for Reconsideration, reiterating that petitioner failed to establish merit in the grounds raised. The court emphasized the qualifications of Amparo, the lack of objection from nearest kin, and the contrast between petitioner’s hostility and respondent’s apparent suitability.
Court of Appeals Ruling and Reasoning
On appeal, the CA affirmed the RTC. The CA found that petitioner failed to prove the authenticity and effect of the letters purporting to show a rift between Julieta and her family. The CA applied the principle that a person with antagonistic interests should not be appointed guardian but concluded there was no demonstration of antagonistic interests between Amparo and Julieta. The CA found no evidence Amparo’s past business decisions prejudiced Julieta, and it rejected the contention that Amparo was hostile to Julieta’s best interests. The CA also noted that petitioner initially concealed the deterioration of Julieta’s mental state from the court and that petitioner’s advanced age militated against her assuming guardianship. The CA observed that those recommended by petitioner as alternative guardians had not indicated willingness to serve.
Issue Presented in the Petition for Review
Petitioner argued that the CA decided substantive questions contrary to law and applicable Supreme Court decisions and that the CA departed from proper judicial procedure in affirming the RTC. Specifically, petitioner asserted (a) the CA’s conclusion that there were no antagonistic interests between petitioner and respondent was contrary to the record, (b) the CA erred in holding there was no showing respondent was hostile to Julieta’s best interests, and (c) appointed representatives designated by Julieta were more suitable guardians.
Legal Standard on Reviewability by Certiorari
The Supreme Court reiterated the settled rule that Rule 45 certiorari is confined to questions of law; questions of fact are not ordinarily proper subjects for certiorari. The test is whether the appellate court can determine the issue without reviewing or reevaluating evidence — if not, the issue is factual. The Court noted the recognized exceptions to the rule against review of factual findings but found that petitioner’s claims primarily required reexamination and reassessment of factual evidence and credibility, which are not proper on certiorari unless an exception clearly applies.
Analysis of Evidence Relied Upon by Petitioner (Letters)
The Supreme Court reviewed the letters petitioner proffered as showing a rift or antagonistic interests and found them insufficient to establish antagonism or unsuitability:
- The first letter reflected Julieta’s wish to divide investments and enjoy funds given her age, which the Court characterized as a lack of interest in future investments rather than a business disagreement amounting to
Case Syllabus (G.R. No. 147148)
Procedural History
- Case originates from Special Proceeding No. N-4375 in the Regional Trial Court (RTC) of Makati, Branch 149, concerning the appointment of a guardian for Julieta Ledesma.
- On July 8, 1996, respondent Amparo Ledesma Gustilo filed a "Petition for Letters of Guardianship" over the person and properties of her sister, Julieta Ledesma (Records, pp. 1-3).
- Pilar Y. Goyena (identified in the caption as petitioner) filed an Opposition and later an Amended Opposition (filed August 15, 1996) to the petition for guardianship.
- By Decision dated October 4, 1996, the RTC found Julieta incompetent and incapable of taking care of herself and her property, and appointed Amparo (referred to in the RTC decision as petitioner Amparo Gustilo) as guardian over Julieta’s person and properties, ordering the filing of a bond of P200,000.00 (Records, pp. 303-308).
- A Motion for Reconsideration filed by the oppositor (Pilar) was denied by order dated November 4, 1996 (Records at 321).
- Petitioner appealed to the Court of Appeals. By Decision dated June 19, 2000, the Court of Appeals affirmed the RTC decision (CA Id., pp. 197-201).
- Petitioner filed a Motion for Reconsideration with the Court of Appeals, which was denied, and subsequently filed a petition for review on certiorari to the Supreme Court (G.R. No. 147148).
- The Supreme Court resolved the petition by Decision dated January 13, 2003, dismissing the petition for lack of merit and affirming the lower courts’ rulings. Justices Puno (Chairman), Panganiban, Sandoval-Gutierrez, and Corona concurred.
Factual Allegations in the Guardianship Petition (as pleaded by respondent)
- Julieta Ledesma had been, for much of 1995 and 1996, a patient at Makati Medical Center, under medical attention for old age, general debility, and an "aminia-stroke" suffered in the United States in early 1995 (Records, pp. 1-3).
- Julieta was confined to bed, unable to get up without assistance, and required a wheelchair for movement.
- Julieta owned real estate and personal properties in Metro Manila and in Western Visayas, with an aggregate estimated assessed and par value of P1,000,000.
- Julieta was alleged to be unable to care for herself and to need assistance of a guardian to manage interests in ongoing corporate and agricultural enterprises.
- The nearest of kin were listed as Julieta’s full-blood sisters: Amparo Ledesma Gustilo (respondent), Teresa Ledesma (aka Sister Cristina of the Religious of the Assumption), and Loreto Ledesma Mapa, who had given their consent to the filing of the petition, as evidenced by their signatures at the bottom of the petition.
- Respondent alleged that she had extensive experience in business management of commercial, agricultural and corporate enterprises, including entities in which Julieta held interests, and that she was positioned to monitor and supervise Julia’s medical needs.
Content of the Opposition and Amended Opposition (filed by Pilar Y. Goyena)
- The Opposition contended that the petition lacked factual and legal basis because Julieta was competent and sane and could take charge of her own affairs; copies of Julieta’s recent letters were attached as Annexes aAa to aE to support this contention.
- The Oppositor argued that she (Pilar) was not fit to be appointed guardian because their interests were antagonistic, citing Sudler v. Sudler and Rule 93, Sec. 4 of the Revised Rules of Court as authority.
- The Opposition prayed for dismissal of the petition for lack of legal and/or factual basis.
- In the remote event that the court found Julieta incompetent, the Opposition proposed alternative individuals deemed suitable to serve as guardian, including: Goyena (Pilar), Bart Lacson, Fely Montelibano, Jose T. Revilla, or another qualified and reputable person as determined by the court.
Trial Court Findings and Ratiocination (RTC Decision, October 4, 1996)
- The RTC found Julieta incompetent and incapable of taking care of herself and her property, concluding she suffered from senility and "avascular dementia."
- The RTC described relevant personal relationships and capacities:
- Amparo (referred to in the decision as petitioner Amparo Gustilo) was 72 years old and the youngest sister of Julieta.
- Oppositor Pilar Goyena was 90 years old, and had been Julieta’s close friend and companion for 61 years.
- Julieta had suffered prior strokes, including one in Makati in 1991 and another in the U.S.
- Julieta had to give up management of their hacienda in Bacolod after the 1991 stroke.
- The RTC noted the special bond between Julieta and Pilar but found that Pilar’s mere conjecture that Amparo disliked her did not make Amparo unsuitable to act as guardian.
- The RTC observed a potential adverse interest in Pilar, citing an allegation that 50% of Julieta’s holdings at Makati Medical Center had been transferred to Pilar (Exhibit 1 and Exhibit A), suggesting Pilar could have adverse interests.
- The RTC concluded that Amparo’s qualifications to act as guardian were duly established and that, as a sister, she could best take care of Julieta’s concerns and well being.
- The court also considered Pilar’s advanced age (90) as militating against her physical fitness to attend to Julieta’s needs.
- Result: Amparo was appointed guardian of Julieta’s person and property with all powers and duties specified under the law, subject to posting a bond of P200,000.00.
RTC Order on Motion for Reconsideration
- Pilar’s (Oppositor’s) Motion for Reconsideration was denied by Order dated November 4, 1996.
- The trial court reaffirmed Amparo’s suitability, noting no meritorious grounds in the motion and reiterating that Amparo appeared most qualified after considering qualifications of the oppositor and other nominees, and that Amparo’s appointment was not objected to by any of Julieta’s nearest kin.
Court of Appeals Decision and Rationale (affirming RTC)
- The Court of Appeals reviewed the record and affirmed the trial court's judgment.
- Key points in the CA’s ratiocination: