G.R. No. 183053 - Suntay III vs. Cojuangco-Suntay

Case Summary (G.R. No. 183053)

Factual Background

Cristina died intestate on June 4, 1990, survived by her husband Federico and several grandchildren. Her only son, Emilio I, predeceased her in 1979. Emilio I’s marriage to Isabel Cojuangco produced three legitimate children (Isabel, Margarita, Emilio II) and was later annulled. Emilio I also fathered two illegitimate children by other women: Emilio III and Nenita. Emilio III was reared from infancy by Cristina and Federico and was acknowledged as a natural child of Emilio I. Federico adopted Emilio III on September 27, 1993.

Petition for Letters of Administration and Initial Allegations

On October 26, 1995, respondent Isabel petitioned for letters of administration alleging that the decedent left an estate of real and personal properties and listing as surviving heirs the surviving spouse (Federico) and three legitimate grandchildren (Isabel, Margarita, Emilio II). The petition did not list Emilio III and Nenita.

Opposition and Intervention by Federico and Emilio III

Federico opposed the petition, asserting his right and preference as surviving spouse to administer the estate, contesting the completeness of the list of heirs and other allegations. Federico later nominated his adopted son, Emilio III, as administrator; Emilio III was allowed to intervene and filed an opposition in intervention echoing Federico’s position and asserting his own qualifications to administer the estate. Federico died on November 13, 2000, during the proceedings.

RTC Trial and Decision

After trial, the RTC found that it was in the best interest of the estate to appoint Emilio III as administrator. The court emphasized the estrangement between the decedent’s legitimate descendants and the decedent’s household, the decedent’s and surviving spouse’s apparent wishes (including nomination by Federico), and Emilio III’s upbringing, training and business experience. The RTC therefore appointed Emilio III as administrator conditioned on bond and inventory requirements.

Court of Appeals Reversal

The CA reversed the RTC, revoked any letters issued to Emilio III, and appointed respondent Isabel as administratrix. The CA’s reasoning focused on: (1) the nomination of Emilio III by Federico being subject to a suspensive condition (Federico’s appointment), rendering the nomination inoperative upon Federico’s death before his own appointment; (2) Article 992 of the Civil Code, which bars illegitimate children from inheriting ab intestato from legitimate relatives of their father or mother, thus disqualifying Emilio III from being preferred over a legitimate grandchild; and (3) the absence of statutory disqualifications under Rule 78 Section 1 for Isabel to serve.

Issues on Appeal to the Supreme Court

Emilio III appealed to the Supreme Court raising principally: (A) whether Article 992 of the Civil Code applies in the appointment of an administrator under Section 6 of Rule 78 of the Rules of Court; and (B) whether, under the undisputed facts that Emilio III was reared by the decedent and her spouse from infancy and later adopted by the surviving spouse, Article 992 should bar him from appointment as administrator.

RTC’s Rationale Emphasized by Petitioner

The RTC’s decision emphasized (1) the presumed wishes of the decedent to treat Emilio III as her own given the rearing from infancy; (2) the nomination by the surviving spouse Federico as indicating preference; and (3) the practical advantages of Emilio III’s management experience for preserving and administering the estate. The RTC also noted the ongoing estrangement between respondent’s immediate family and the decedent’s household.

Supreme Court’s Review of Article 992 and the CA’s Application

The CA relied on Article 992 to exclude Emilio III because he was an illegitimate descendant of the decedent’s son and thus, per the “iron curtain” rule, could not inherit ab intestato from legitimate relatives. The Supreme Court found this application erroneous on the facts: the Court observed that Emilio III was reared and treated by the decedent and her husband akin to a legitimate relative and was legally adopted by the surviving spouse, which altered his legal relationship and interest in the estate.

Supreme Court’s Analysis on Order of Preference and Judicial Discretion

The Supreme Court reiterated that Section 6, Rule 78 lists a preferred order for granting administration but the preference is not absolute; selection of an administrator remains within the trial court’s sound discretion, guided by the best interest of the estate and the presumed wishes of the decedent. The Court cited precedent recognizing trial court discretion and the viability of co‑administration where justice and equity demand representation of opposing factions.

Application of Successional Principles and the Role of Adoption

The Supreme Court applied the foundational principle that intestate succession follows the presumed will of the decedent—calling first descendants and those closer in degree. The Court accepted petitioner’s factual showing that the decedent and surviving spouse treated Emilio III as their own, and it gave material weight to Federico’s legal adoption of Emilio III, which conferred direct succession rights from Federico and a distinct legal interest in the estate apart from representation of his decease

Case Syllabus (G.R. No. 183053)

Procedural Posture

Petition for review on certiorari under Rule 45 of the Rules of Court assailing the Decision of the Court of Appeals in CA-G.R. CV No. 74949, which reversed the Regional Trial Court (RTC), Branch 78, Malolos, Bulacan, in Special Proceeding Case No. 117-M-95.
Trial court (RTC) appointed petitioner Emilio A.M. Suntay III (Emilio III) as administrator of the intestate estate of Cristina Aguinaldo-Suntay (Cristina).
Court of Appeals reversed the RTC, revoked Letters of Administration issued to Emilio III, and appointed respondent Isabel Cojuangco-Suntay (Isabel) as administratrix.
Emilio III sought review by certiorari to the Supreme Court, raising specific issues regarding the applicability of Article 992 of the Civil Code and his qualification given the fact he was reared by the decedent and her spouse from infancy.
Supreme Court granted the petition, reversed the Court of Appeals, and ordered joint issuance of Letters of Administration to both Emilio III and Isabel, with further directions to the RTC.

Relevant Dates and Case Identifiers

Decedent Cristina died intestate on June 4, 1990.
The only son of Cristina and Federico, Emilio Aguinaldo Suntay (Emilio I), predeceased them in 1979.
Federico adopted Emilio III and Nenita on September 27, 1993.
Respondent Isabel filed the petition for letters of administration on October 26, 1995.
Federico filed opposition to Isabel’s petition on December 21, 1995.
Federico filed a manifestation nominating Emilio III as administrator on March 13, 1999.
Federico died on November 13, 2000.
RTC rendered decision appointing Emilio III on November 9, 2001.
Supreme Court Decision promulgated June 15, 2010 (G.R. No. 183053).

Facts — Family Relationships and Personal Histories

Cristina Aguinaldo-Suntay (decedent) was married to Dr. Federico Suntay (Federico).
Their only son, Emilio I, died in 1979, predeceasing Cristina and Federico.
During his lifetime, Emilio I married Isabel Cojuangco; they had three children: Isabel (respondent), Margarita, and Emilio II, all surnamed Cojuangco-Suntay.
The marriage between Emilio I and Isabel Cojuangco was subsequently annulled.
Emilio I had two children out of wedlock by different women: Emilio III (by Concepcion Mendoza) and Nenita Suntay TaAedo (by Isabel Santos).
Emilio III and Nenita were acknowledged natural children of Emilio I and were reared by Federico and Cristina from infancy.
Emilio III was raised by Cristina and Federico since he was nine months old; he was acknowledged as Emilio I’s natural child and later legally adopted by Federico on September 27, 1993.
Respondent Isabel and her siblings lived with their mother separately from their father and paternal grandparents after annulment; estrangement persisted for over thirty years.
Federico sought visitation rights to see his grandchildren during his son’s lifetime; visitation was initially granted but later stopped after a manifestation by respondent Isabel.

Petition for Letters of Administration — Allegations and Contents

On October 26, 1995, respondent Isabel filed a petition for issuance of letters of administration alleging:
- At death, Cristina was a resident of Hagonoy, Bulacan.
- The estate comprised real and personal properties with a probable gross value of P29,000,000.00.
- Surviving heirs listed: (1) Federico C. Suntay (surviving spouse, 89), (2) Isabel Cojuangco-Suntay (36, legitimate granddaughter), (3) Margarita (39, legitimate granddaughter), and (4) Emilio Cojuangco-Suntay (35, legitimate grandson).
- As far as petitioner knew, the decedent left no debts or obligations.
Petitioner’s listing and characterization of heirs omitted mention of Emilio III and Nenita.

Opposition by Federico and Intervention by Emilio III

Federico filed opposition (Dec. 21, 1995) denying petition allegations and asserting:
- As surviving spouse, he was capable and should be appointed administrator.
- As part-owner of conjugal property, he must be given legal preference in administration.
- Isabel and her family had been alienated from their grandparents for more than thirty years.
- The petition omitted other children of his son (Emilio III and Nenita).
- He was better situated to protect and manage the estate, having managed conjugal properties even before Cristina’s death.
- The alleged estate valuation was grossly overstated and claims of usurpers were untrue.
After failed settlement attempts, Federico nominated his adopted son Emilio III as administrator in a Manifestation dated March 13, 1999.
The RTC granted Emilio III leave to intervene; Emilio III filed Opposition-In-Intervention alleging:
- He and/or Federico were better equipped to administer the estate than respondent Isabel.
- Emilio III’s qualifications: engaged in aquaculture and banking, trained by the decedent, work experience with Emilio Aguinaldo Foundation, employment post-graduation at F.C.E. Corporations and Hagonoy Rural Bank, educational and managerial experience set out in his curriculum vitae.

Trial Court Findings and Decision (RTC, Branch 78)

After evidence and testimony, RTC appointed Emilio III as administrator and ordered bond in the amount of P200,000.00 conditioned on inventory, administration and payment of debts, accounts, and obedience to court orders.
RTC’s reasoning emphasized:
- Best interest of the estate and its claimants warranted the appointment of Emilio III.
- The estrangement between respondent’s immediate family and the decedent’s family favored an administrator aligned with decedent’s wishes and family harmony.
- Appointment of petitioner would go against the wishes of the decedent who raised Emilio III from infancy and against the wishes of the surviving spouse who nominated Emilio III.
- Surviving spouse Federico was accorded statutory preference under Sec. 6(a), Rule 78; his nomination of Emilio III deserved weight and should not be set aside without valid reason even after Federico’s death.
- From the estate’s perspective, Emilio III’s academic and managerial experience gave him an advantage in administering and preserving the estate over respondent Isabel, a practicing physician.

Court of Appeals Decision and Reasoning

Court of Appeals reversed RTC and set aside its decision, revoked any Letters of Administration issued to Emilio III, and appointed respondent Isabel as administratrix upon filing of a bond of P200,000.00.
CA’s principal reasons included:
- Federico’s nomination of Emilio III was conditional on Federico’s appointment as administrator; Federico’s death before appointment rendered the nomination inoperative.
- Between legitimate offspring (respondent Isabel) and illegitimate offspring (Emilio III) of Emilio I, respondent is preferred as “next of kin” under Section 6, Rule 78 and entitled to share in Cristina’s estate.
- Cited Article 992 of the Civil Code: “An illegitimate child has no right to inherit ab intestato from the legitimate children and relatives of his father or mother; nor shall such children or relatives inherit in the same manner from the illegitimate
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