View full case

PILAR Y. GOYENA v. AMPARO LEDESMA-GUSTILO

FACTS:

Julieta Ledesma, the ward in this case, had been a patient in the Makati Medical Center due to old age, general debility, and a mini-stroke. She was confined to her bed and required outside assistance to move. She owned real estate and personal properties with an estimated value of P1 million. She was not in a position to care for herself and needed a guardian to manage her interests in various enterprises. Her sisters, including Amparo Ledesma Gustilo, the petitioner in this case, consented to the filing of a petition for guardianship.

Pilar Y. Goyena, a close friend and companion of Julieta for over 60 years, filed an opposition to the petition. She argued that there was no need to appoint a guardian for Julieta as she was competent and capable of taking care of herself. Goyena also claimed that Amparo had a conflict of interest as she disliked her. She proposed alternative choices for the guardian.

The trial court found Julieta incompetent and appointed Amparo as her guardian. It noted the special bond between Julieta and Goyena but found Goyena's objections unfounded. The court also considered Amparo's qualification as a sister and her ability to care for Julieta's concerns. The court denied Goyena's motion for reconsideration.

On appeal, the Court of Appeals affirmed the trial court's decision. It noted that there was no evidence to support Goyena's claims of a rift between Julieta and her family. It also found no indication that Amparo had a hostile interest towards Julieta. The Court of Appeals considered Goyena's age and her lack of interest in assuming the guardianship role. It also found that the proposed alternative guardians had not expressed their desire to act as such.

ISSUES:

  1. Whether the Court of Appeals erred in finding that there are no antagonistic interests between the petitioner and respondent.

  2. Whether the Court of Appeals erred in holding that there is no showing that the respondent is hostile to the best interest of Julieta.

  3. Whether Julieta Ledesma's appointed representatives are more suitable to be appointed as her guardian.

  4. Whether or not there exist antagonistic interests between the petitioner and respondent to render the latter unsuitable for appointment as guardian.

  5. Whether or not the respondent's intent in instituting the guardianship proceedings is to take control of the petitioner's properties and use them for her own benefit.

  6. Whether or not the respondent is hostile to the best interests of the petitioner.

RULING:

  1. The Supreme Court affirmed the decision of the Court of Appeals, stating that the issues raised by the petitioner required a review of the evidence, which is not proper under a petition for certiorari under Rule 45. It is well-established that certiorari is confined to questions of law. The Court also noted that the petitioner admitted in her Reply that the issues raised were factual. The Court held that it could not go over the evidence presented by the parties and determine if the trial court and appellate court were correct in their assessments.

  2. The Court held that there is no evidence to establish the existence of antagonistic interests between the petitioner and respondent. The letters presented by the petitioner do not demonstrate a business disagreement nor antagonistic interests that would render the respondent unsuitable for appointment as guardian.

  3. The Court found that the petitioner's assertion that the respondent's intent in instituting the guardianship proceedings is to take control of the petitioner's properties and use them for her own benefit is purely speculative and unsupported by the records.

  4. The Court rejected the claim that the respondent is hostile to the best interests of the petitioner, as the removal of the petitioner from the medical center does not necessarily indicate hostility, especially considering that the petitioner was still under medical care and was returned to the hospital when she suffered another stroke.

PRINCIPLES:

  • Questions of fact are not proper subjects of appeal by certiorari under Rule 45 of the Rules of Court.

  • The Supreme Court's jurisdiction under a Rule 45 petition is limited to reviewing and revising only errors of law.

  • The selection of a guardian is within the discretion of the judge, and his or her decision should not be disturbed unless there is a clear showing of grievous error.

  • The interests of a guardian should not be antagonistic to the best interests of the ward.

  • The appointment of a guardian should not be based on speculative claims and should be in the best interests of the ward.

  • Lack of evidence establishing antagonistic interests and hostile intent may render the claim for unsuitability of a guardian lacking in merit.

  • Concealing relevant information and lack of good faith may affect the credibility of a petitioner's claim.

  • The suitability of a guardian for appointment should be based on the facts and evidence presented before the court.