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LEONIDA CORONADO v. CA

FACTS:

The case involves a 277 square meter parcel of land in Nagcarlan, Laguna, which is claimed by Juana Albovias. She asserts that the property is a portion of a larger lot called Parcel G, which she and her brother Domingo Bueno inherited. According to Juana, C. Lirio street was established in 1925 or 1926, dividing the land into two sections. The northern portion was given to the Formentera heirs, while the southern portion was awarded to Juana and Domingo Bueno.

Domingo later sold his portion to Dalmacio Monterola, who owned the adjacent property. Juana claims that her portion of the land was included in the sale of Monterola's lots to Leonida Coronado, who subsequently sold it to Melania Retizos. Retizos then sold the property to Bernardino Buenaseda and Jovita Montefalcon, the current possessors.

On the other hand, Leonida Coronado argues that the property was bequeathed to her by Dr. Dalmacio Monterola through a will. In response, Juana filed a lawsuit against Coronado, seeking quieting of title, declaratory relief, and damages. The trial court ruled in favor of Juana, a decision that was later affirmed by the Court of Appeals. Coronado then filed a petition for review on certiorari with the Supreme Court, contesting several assigned errors. However, the Supreme Court found these errors to be without merit.

ISSUES:

  1. Whether the property in question was bequeathed to Leonida Coronado under a will executed by Dr. Dalmacio Monterola.

  2. Whether there is evidence to show that the property claimed by private respondent Juana Albovias is the same property adjudicated to her under the will of Melecio Artiaga.

  3. Whether private respondent Juana Albovias is estopped from questioning the ownership of the petitioners over the land in question.

  4. Whether the respondent appellate court committed grave and serious error in appreciating the evidence submitted and facts admitted on record.

RULING:

  1. The petition is devoid of merit.

PRINCIPLES:

  • A will must be proved and allowed by the probate court before it can have any effect (Issue 1).

  • The party seeking to establish the existence of a will has the burden of establishing its due execution (Issue 1).

  • The probate court's judgment on the allowance or disallowance of a will is limited to determining: (1) whether the will was executed in accordance with the formalities required by law, (2) the testator had testamentary capacity at the time of the execution of the will, (3) the will was executed without fraud or undue influence, and (4) the will was executed freely and voluntarily (Issue 1).

  • The fact that a will has been allowed in probate proceedings does not necessarily mean that all matters embraced in the will have already been settled (Issue 1).

  • The burden of establishing that the property being claimed by the private respondent is the same property adjudicated to her under the will lies upon the private respondent (Issue 2).

  • The principle of estoppel precludes a party from asserting a claim inconsistent with his or her own previous representations (Issue 3).

  • The appellate court's appreciation of evidence and facts presented is entitled to great weight and respect, and its assessment will not be disturbed unless it is shown that it overlooked, misunderstood, or misapplied facts or circumstances of weight and significance (Issue 4).