Case Summary (G.R. No. 217285)
Procedural Background
The case began when Remedios Oribello, represented by her attorney-in-fact Alfredo Selga, filed an action for partition against Berlinda Oribello, the widow of Toribio Oribello, following Toribio's death on August 18, 1993. Remedios contended that she is an adopted daughter of Toribio based on a decree of adoption granted by the Court of First Instance of Occidental Mindoro in 1974. Berlinda, however, disputed this adoption's validity, claiming it was fraudulently obtained and asserting numerous infirmities in the adoption proceedings.
Judgment of the Regional Trial Court
On March 30, 1998, the Regional Trial Court (RTC) dismissed the complaint for partition, determining that Remedios was not a co-owner of the properties belonging to Toribio Oribello, aside from three specific parcels. Additionally, the RTC awarded Berlinda attorney’s fees amounting to ₱25,000.
Appeals to the Court of Appeals
Remedios subsequently appealed the RTC's ruling, arguing against the dismissal and seeking to uphold her claimed rights stemming from the adoption decree. On July 31, 2003, the Court of Appeals vacated the RTC's judgment and remanded the case for a second phase of the partition suit, emphasizing the RTC’s lack of authority to annul the adoption decree.
Legal Issues Presented
This appeal presents several core issues:
- Whether there was grave abuse of discretion in the CA's decision allowing Remedios to pursue a claim based on the alleged adoption.
- Whether Remedios's claims can stand despite the allegations of fraudulent circumstances surrounding her adoption.
- The distinction between the authority of the RTC and the appellate courts in reviewing the annulment of judgment.
Ruling of the Supreme Court
The Supreme Court found merit in Berlinda's appeal, overturning the CA's decision. The Court reiterated that the validity of the adoption decree from the CFI could not be challenged within the partition action due to the risk of a collateral attack. Instead, any such challenge must be addressed through a direct action for annulment in the proper jurisdiction, which the CA had the exclusive authority to adjudicate.
Furthermore, the Court emphasized that Remedios failed to discharge her burden of proof to substantiate her cla
...continue readingCase Syllabus (G.R. No. 217285)
Overview
- The case involves an appeal by Berlinda Oribello, the surviving spouse of the deceased registered owner of certain properties, challenging the decision of the Court of Appeals (CA).
- The appeal arises from a partition suit concerning twelve parcels of land located in Sta. Rita, Agoo, La Union, which were owned by Toribio Oribello, the deceased husband of Berlinda.
- The CA had vacated and set aside the Regional Trial Court's (RTC) judgment that dismissed the partition complaint filed by Remedios Oribello, who claims to be the adopted daughter of Toribio Oribello.
Antecedents
- The RTC in La Union was initially presented with the partition suit, wherein the ownership of twelve parcels of land was contested.
- The ownership details indicated that eight parcels were registered under Toribio Oribello, while others were shared with various individuals, including Berlinda and another spouse, Rosenda.
- Toribio's first marriage to Emilia was dissolved in 1981, and he remarried Berlinda in 1982 before passing away intestate in 1993.
- Remedios Oribello, represented by her father Alfredo Selga, filed the complaint asserting her rights based on a decree of adoption granted in 1974.
Judgment of the RTC
- On March 30, 1998, the RTC dismissed Remedios' claim, ruling that she was not a co-owner of the disputed