Title
Vda. de Chua vs. Court of Appeals
Case
G.R. No. 116835
Decision Date
Mar 5, 1998
Florita Vallejo sought guardianship and estate administration for Roberto Chua's illegitimate children. Antoinetta Garcia, claiming to be Chua's widow, contested venue and due process. Courts ruled in Vallejo's favor, affirming proper venue, no republication needed, and Garcia's due process rights were upheld.

Case Summary (G.R. No. 116835)

Petition and Initial Proceedings

Florita A. Vallejo filed a petition with the Regional Trial Court (RTC) of Cotabato City on July 2, 1992, for the declaration of heirship, guardianship over her two minor children by Roberto Lim Chua, and for the issuance of letters of administration over the decedent’s estate. Vallejo asserted that the decedent died intestate, was single at the time of death, and that her two minor children were his sole heirs under Article 988 of the Civil Code of the Philippines. She also prayed for guardianship of the minors and the administration of the estate.

Motion to Dismiss and Opposition

Antonietta Garcia Vda. de Chua filed a Motion to Dismiss the petition on grounds of improper venue, arguing that Davao City, where the decedent died and purportedly resided, is the proper forum, not Cotabato City. Private respondent opposed this motion, contending that the petition primarily concerns the guardianship of the minor children, whose residence is in Cotabato City, and thus venue lies in the RTC of Cotabato City under Section 1, Rule 92 of the Rules of Court. She also denied petitioner’s status as the surviving spouse, claiming that the decedent died unmarried.

Trial Court’s Denial of Motion to Dismiss

The RTC denied the motion to dismiss based on several findings:

  • Petitioner failed to prove the existence of a valid marriage with the deceased, as she did not present the original marriage certificate nor authenticated copies.
  • Evidence submitted by the petitioner, including residency certificates and tax returns, failed to establish a valid marriage.
  • The RTC found Cotabato City as the decedent’s actual residence, especially since the minors lived there.
  • The court ruled that the place of residence does not confer jurisdiction but constitutes venue and that the RTC first assuming cognizance shall exercise jurisdiction to the exclusion of other courts under Section 1, Rule 73 of the Rules of Court.

Subsequent Orders and Appointments by the RTC

On August 31, 1992, the RTC appointed Romulo Lim Uy, a relative of the deceased, as special administrator of the estate and Florita Vallejo as guardian over the person and properties of the minor heirs. Several court orders were issued directing the transfer of the decedent’s remains to Cotabato City, the turnover of estate property, and the conduct of an inventory — all without prior notice to petitioner.

Petitioner’s Motions for Recall and Reconsideration

Petitioner filed motions requesting the recall of letters of administration and the nullification of proceedings as mistrials. These motions were denied by the RTC, including an order denying reconsideration.

Petition for Certiorari to the Court of Appeals

Petitioner filed a petition for certiorari and prohibition with the Court of Appeals (CA), arguing:

  1. The RTC acted with grave abuse of discretion in converting the guardianship petition into intestate estate proceedings.
  2. The RTC issued Letters of Administration and proceeded without jurisdiction or notice, violating due process.
  3. The CA erred in holding that the remedy against the RTC’s orders should be an appeal rather than certiorari.

Court of Appeals' Ruling

The CA affirmed the RTC’s decisions for the following reasons:

  • The original petition was for both guardianship and settlement of the intestate estate, as reflected in its title and pleadings.
  • There was no need to publish the amended petition because the same material averments were contained in the original petition and proper notice had been given.
  • Petitioner lacked legal personality or interest (locus standi) to file a motion to dismiss or oppose the petition because she was neither an heir, creditor, nor spouse, since the existence of marriage was unproven.
  • The petition complied substantially with jurisdictional requirements under Section 2, Rule 79 of the Rules of Court despite minor omissions cured by the amended petition.
  • Due process was observed as petitioner was afforded an opportunity to be heard through her motions for recall and reconsideration, which were denied after hearings.
  • The proper remedy for challenging the RTC’s orders was an ordinary appeal, not certiorari or prohibition, which are extraordinary remedies reserved when no plain, speedy, and adequate remedy exists.

Supreme Court Analysis and Ruling

The Supreme Court upheld the CA’s decision, emphasizing:

  • The original petition explicitly prayed for both guardianship and letters of administration with the corresponding jurisdictional facts.
  • The failure to produce a valid marriage contract by petitioner weighed heavily against her claim as surviving spouse.
  • Evidence presented by petitioner failed to establish marriage, as documents such as land titles, tax returns, and passports do not prove marital status.
  • The decedent’s residence was deemed Cotabato City for venue purposes, considering the residence of the minor children and the nature of the case.
  • Due process requires an opportunity to be heard, not necessarily a hearing prior to every court order. Petitioner was given adequate op

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