FACTS:
The petitioners sought the settlement of the intestate estate of their brother, Ricardo de Mesa Abad, claiming to be his only heirs. They later amended their petition to claim that the properties actually belonged to their late mother, Lucila de Mesa. The trial court appointed Cesar de Mesa Tioseco as the administrator of Ricardo's estate.
However, private respondents filed a motion alleging that Honoria Empaynado, Ricardo's common-law wife, and their two children, Cecilia and Marian Abad Empaynado, were the true heirs of Ricardo. They also revealed the existence of another child, Rosemarie Abad, allegedly fathered by Ricardo with another woman. Private respondents accused petitioners of concealing the existence of these three children in order to deprive them of their rights to Ricardo's estate.
Private respondents filed a motion to annul the extrajudicial partition executed by petitioners, as well as the Torrens titles and real estate mortgages issued in substitution of the original titles. The lower court ruled in favor of private respondents, declaring Cecilia, Marian, and Rosemarie as the acknowledged natural children and the only surviving legal heirs of Ricardo Abad. The court appointed Honoria Empaynado as the administratrix of the estate and ordered Cesar Tioseco to surrender all property, money, and papers that came into his possession as administrator. The court also annulled certain documents related to the partition of the estate.
The case involves a dispute over the estate of the deceased Lucila de Mesa and the ownership of certain parcels of land. The trial court declared the Extra Judicial Settlement of the Estate of Lucila de Mesa executed by the petitioners and Carolina de Mesa Abad-Gonzales, as well as the cancellation of certain titles and the issuance of new ones, to be inexistent and void from the beginning. The court ordered the Register of Deeds of Manila to cancel the erroneous titles and restore or issue the corresponding title in the name of Ricardo Abad, one of the petitioners. The court also declared three real estate mortgages executed by the petitioners and Carolina de Mesa Abad-Gonzales to be inexistent and void from the beginning and ordered the cancellation of their registration or annotation on the back of Ricardo Abad's torrens title. Furthermore, the court directed Atty. Escolastico R. Viola and his wife, Josefina C. Viola, to surrender the titles in question to the new administratrix of the estate. The petitioners' motion for reconsideration and notice of appeal were both denied by the trial court. As a result, the petitioners filed certiorari and mandamus proceedings with the Court of Appeals, which initially granted their petition but later dismissed their appeal for being filed out of time. This led the petitioners to file another certiorari and mandamus proceedings with the Court of Appeals, which affirmed the dismissal of their appeals. The petitioners then appealed to the Supreme Court, which directed the trial court to give due course to their appeal. As a result, the two appeals were elevated to the appellate court, which ultimately denied the appeal and affirmed the orders of the trial court.
ISSUES:
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Whether respondents Cecilia E. Abad, Marian E. Abad, and Rosemarie S. Abad are the acknowledged natural children of the deceased Ricardo de Mesa Abad.
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Whether petitioners are entitled to the subject estate, whether the same is owned by the deceased Ricardo de Mesa Abad or by Lucila de Mesa, the mother of both petitioners and Ricardo de Mesa Abad.
RULING:
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The Supreme Court affirmed the finding of the trial court and the Court of Appeals that respondents Cecilia Abad, Marian Abad, and Rosemarie Abad are indeed the acknowledged natural children of the deceased Ricardo de Mesa Abad.
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The Supreme Court ruled that since the properties were proven to belong to Ricardo Abad, petitioners are precluded from inheriting the estate of their brother given the provisions of Art. 988 and Art. 1003 of the Civil Code. Furthermore, the Court held that petitioners’ claim that the properties in the name of Ricardo Abad actually belong to their mother Lucila de Mesa was unsupported.
The Supreme Court also set aside the affirmance of the order dated March 21, 1975 denying the appeal of Dolores de Mesa Abad and Cesar de Mesa Tioseco on the ground that it had been filed out of time.
PRINCIPLES:
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Factual Findings of Lower Courts: Factual findings of the trial court, adopted and confirmed by the Court of Appeals, are final and conclusive and may not be reviewed on appeal unless a significant fact had been overlooked or misinterpreted that would affect the outcome of the case.
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Best Evidence Rule: When disputing the date of death or any critical fact, the best evidence (such as a death certificate) must be presented rather than secondary evidence like affidavits or statements.
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Confidential Communication Privilege: Statements made by a patient to a physician are privileged, even after the patient’s death, if revealing them would tend to blacken the patient's reputation.
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Rules on Inheritance:
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Art. 988, Civil Code: In the absence of legitimate descendants or ascendants, the illegitimate children shall succeed to the entire estate of the deceased.
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Art. 1003, Civil Code: If there are no illegitimate children or a surviving spouse, the collateral relatives shall succeed to the entire estate of the deceased.
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Binding Supreme Court Decisions: A ruling by the Supreme Court is binding on lower courts and must be followed. Lower courts cannot reverse or disregard such rulings.