ANCHETA V. GUERSEY-DALAYGON (Succession)

Binding Effect of Judgments
490 SCRA 140
June 8, 2006

Facts: Spouses Audrey O’Neill (Audrey) and W. Richard Guersey (Richard) were American citizens who have resided in the Philippines for 30 years. They have an adopted daughter, Kyle Guersey Hill (Kyle). Audrey died in 1979. She left a will wherein she bequeathed her entire estate to Richard consisting of Audrey’s conjugal share in real estate improvements at Forbes Park, current account with cash balance and shares of stock in A/G Interiors. Two years after her death, Richard married Candelaria Guersey-Dalaygon. Four years thereafter, Richard died and left a will wherein he bequeathed his entire estate to respondent, except for his shares in A/G, which he left to his adopted daughter.

Petitioner, as ancillary administrator in the court where Audrey’s will was admitted to probate, filed a motion to declare Richard and Kyle as heirs of Audrey and a project of partition of Audrey’s estate. The motion and project of partition were granted. Meanwhile, the ancillary administrator with regards to Richard’s will also filed a project of partition, leaving 2/5 of Richard’s undivided interest in the Forbes property was allocated to respondent Candelaria, while 3/5 thereof was allocated to their three children. Respondent opposed on the ground that under the law of the State of Maryland, where Richard was a native of, a legacy passes to the legatee the entire interest of the testator in the property subject to the legacy.

Issue: Whether or not the decree of distribution may still be annulled under the circumstances.

Held: A decree of distribution of the estate of a deceased person vests the title to the land of the estate in the distributees, which, if erroneous may be corrected by a timely appeal. Once it becomes final, its binding effect is like any other judgment in rem.

However, in exceptional cases, a final decree of distribution of the estate may be set aside for lack of jurisdiction or fraud. Further, in Ramon vs. Ortuzar, the Court ruled that a party interested in a probate proceeding may have a final liquidation set aside when he is left out by reason of circumstances beyond his control or through mistake or inadvertence not imputable to negligence.

Petitioner’s failure to proficiently manage the distribution of Audrey’s estate according to the terms of her will and as dictated by the applicable law amounted to extrinsic fraud. Hence the CA Decision annulling the RTC Orders dated February 12, 1988 and April 7, 1988, must be upheld.