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DELGADO v. HEIRS OF RUSTIA

FACTS:

This case involves the settlement of the intestate estates of Guillermo Rustia and Josefa Delgado. The main issue revolves around determining the lawful heirs of the decedents. The claimants can be divided into two groups: the alleged heirs of Josefa Delgado and the alleged heirs of Guillermo Rustia.

The first issue involves determining the marital status of Felisa Delgado and Ramon Osorio, the parents of Josefa Delgado. This is important because it affects the inheritance rights of Josefa's half-brother, Luis Delgado.

The second issue revolves around the alleged marriage between Guillermo Rustia and Josefa Delgado. There is a dispute as to whether a marriage actually took place.

Guillermo Rustia had a relationship with Amparo Sagarbarria and fathered an illegitimate child, Guillerma Rustia. Guillerma was treated as Guillermo's daughter and had continuous possession of that status.

Luisa Delgado vda. de Danao filed a petition for letters of administration of the intestate estates of Josefa Delgado and Guillermo Rustia. Guillerma Rustia filed a motion to intervene in the proceedings and was granted. The court appointed Carlota Delgado vda. de de la Rosa as administratrix of both estates, ruling that Luisa Delgado vda. de Danao and other claimants were the legal heirs of Josefa Delgado, and Guillerma Rustia was the sole heir of Guillermo Rustia. Oppositors appealed the decision.

The case involves an appeal filed by oppositors challenging the decision of the trial court regarding the partition and administration of the estate of Dr. Guillermo Rustia and Josefa Delgado Rustia. The oppositors' appeal was initially denied due to the late filing of the record on appeal. They filed a petition for certiorari and mandamus, which was dismissed by the Court of Appeals. However, after a motion for reconsideration and oral arguments, the Court of Appeals reversed itself and allowed the continuance of the appeal in the interest of substantial justice. The case was elevated to the Supreme Court for review. The Court affirmed the resolution of the Court of Appeals and allowed the continuance of the appeal. The Court emphasized that while periods for filing appeals must generally be followed, a delay may be excused under exceptional circumstances. The Court also noted that there were substantive matters in the appeal that were improperly denied due to the technical ground of late filing. The Court of Appeals, upon review, partially set aside the trial court's decision based on the merits of the case.

ISSUES:

  1. Whether there was a valid marriage between Guillermo Rustia and Josefa Delgado.

  2. Who the legal heirs of the decedents Guillermo Rustia and Josefa Delgado are.

  3. Who should be issued letters of administration for the intestate estates.

RULING:

  1. The Supreme Court ruled that a valid marriage existed between Guillermo Rustia and Josefa Delgado. Various pieces of evidence such as the certificate of identity issued to Josefa Delgado as Mrs. Guillermo Rustia, the passport issued to her as Josefa D. Rustia, the declaration under oath by Guillermo Rustia of his marriage to Josefa and the titles to properties in the name of "Guillermo Rustia married to Josefa Delgado" supported the presumption of marriage.

  2. Legal Heirs of Josefa Delgado The Court found that Felisa Delgado and Ramon Osorio were never married; thus, all their children, including Josefa Delgado, were natural children. As such, both full- and half-blood siblings could inherit from her estate. However, representation in the collateral line extends only to nephews and nieces, not grandnephews and grandnieces. The trial court was tasked to determine the surviving collateral relatives entitled to inherit from Josefa Delgado.

  3. Legal Heirs of Guillermo Rustia The Supreme Court ruled that neither Guillerma Rustia, as an illegitimate child, nor Guillermina Rustia Rustia, as an ampun-ampunan (informal adopted child), could inherit from Guillermo Rustia. Therefore, the rightful heirs are his surviving sisters Marciana Rustia vda. de Damian and Hortencia Rustia Cruz, and the children of his predeceased brother Roman Rustia Sr.

  4. Letters of Administration Letters of administration for the intestate estates of Guillermo Rustia and Josefa Delgado were to be issued jointly to Carlota Delgado vda. de de la Rosa and a nominee from among the heirs of Guillermo Rustia.

PRINCIPLES:

  1. Presumption of Marriage A long cohabiting couple deporting themselves as husband and wife is presumed to have a lawful marriage unless contradicted by sufficient evidence.

  2. Illegitimate Children Under the old Civil Code, illegitimate children had no hereditary rights. Under the new Civil Code, they still need to be acknowledged for inheritance, and there are specific criteria and methods for such acknowledgment.

  3. Right of Representation in Collateral Line Under Article 972 of the Civil Code, the right of representation in the collateral line extends only to nephews and nieces, not grandnephews and grandnieces.

  4. Extrajudicial Settlement by Affidavit Under Rule 74, Section 1 of the Rules of Court, an heir can settle the estate of a decedent by affidavit only if he or she is the sole heir.

  5. Adoption Rights Adoption in the Philippines must comply with statutory requirements and be judicially decreed. Informal measures or customs like ampun-ampunan do not establish legal rights to inheritance.

  6. Appointment of Administrators The principal consideration is the applicant's interest in the estate, with a preference for next of kin or credible interested persons. Joint administration may be warranted to represent diverse interests.