Reyes v. Sotero
Reyes v. Sotero
SOTERO
G.R. No. 167405 February 16, 2006
J. YNARES-SANTIAGO
Topic: Rules Conferring Power Over Another's Property - Rule 73 Venue and Process
FACTS
1. Elena Lising died and Private Respondent Corazon Chichioco filed a petition for the
issuance of letters of administration and settlement of the estate (Spec. Proc. No.
204 )of the deceased.
4. On the other hand, respondents filed a criminal action against Petitioner for the
alleged falsification of the adoption decree and Judicial Form No. 43, docketed as I.S.
No. 00-1016 before the Office of the Provincial Prosecutor, Tarlac City.
a. The Office of the Provincial Prosecutor found probable cause to charge the
petitioner with falsification but this was appealed by the Petitioner before the
Office of the Regional State Prosecutor.
5. During the pendency of the criminal case, the RTC granted respondents’ motion for the
appointment of a special administrator and appointed its branch clerk of court, Atty.
Saguyod.
a. Petitioner filed a motion for reconsideration but this was denied.
1
pursuant to a decision rendered in SP No. 1410 by Judge Julian Lustre of the CFI of Tarlac, Branch 3, promulgated
on December 21, 1968 and duly registered with the Office of the Civil Registrar on January 29, 1969.
6. Respondents also filed a motion to enjoin Petitioner from conducting business on
the deceased’s estate.
a. The RTC granted this via Resolution on September 18, 2002, enjoining Petitioner
and empowering the Special Administrator to take control and possession of the
deceased’s properties.
b. Petitioner filed a motion for reconsideration, but this was denied on November
12, 2002
7. Meanwhile, the Office of the Regional State Prosecutor and the DOJ, upon review,
reversed the findings of the Provincial Prosecutor and dismissed the criminal charges
against Petitioner.
8. So Petitioner filed a special civil action for certiorari before the CA assailing the
RTC’s September 18, 2002 and November 12, 2002 resolutions.
a. She alleged that said resolutions were issued with grave abuse of discretion
amounting to lack or in excess of jurisdiction since as sole heir, she had the right
to possess and use the decedent’s property, title over which automatically
passed on to her upon the latter’s death.
b. There was also no valid challenge to her adoption and she consequently remains
to be the sole heir of the decedent.
i. Thus, she stressed that there was no need for the appointment of an
administrator or for the settlement proceedings and Corazon’s original
petition (Spec. Proc. No. 204) should be dismissed.
RATIO DECIDENDI
b. ITC, these certifications suffice as proof of the fact of petitioner’s adoption by the
Delos Santos spouses until contradicted or overcome by sufficient evidence.
i. Mere "imputations of irregularities" will not cast a "cloud of doubt" on the
adoption decree since the certifications and its contents are presumed
valid until proof to the contrary is offered.
- Other SC notes:
- To allow the proceedings below to continue would serve no salutary purpose but
to delay the resolution of the instant case.
- After all, the dismissal of Spec. Proc. No. 204 is the logical consequence of our
pronouncement relative to the presumed validity of petitioner’s adoption.
- All the evidence pertinent to the resolution of the petitioner’s opposition, which is
actually a motion to dismiss the petition for letters of administration and
settlement of the estate, is a matter of record in the instant case.
- The same has in fact been submitted for resolution before the RTC more
than six years ago and is so far the only pending incident before the RTC.
- No useful purpose will thus be served if we let the RTC resolve the matter, only
for its ruling to be elevated again to the Court of Appeals and subsequently to this
Court.
- The remand of the case to the lower court for further reception of
evidence is not necessary where the Court is in a position to resolve the
dispute based on the evidence before it.