G.R. No. 116835 March 5, 1998
ANTONIETTA GARCIA VDA. DE CHUA, petitioner, vs. COURT OF APPEALS (Special Eight Division), HON. JAPAL M. GUIANI, RTC, Branch 14, 12th Judicial Region, Cotabato City, and FLORITA A. VALLEJO, as Administratrix of the Estate of the late Roberto L. Chua, respondents.

FACTS

Roberto Lim Chua died intestate on May 28, 1992. During his lifetime, he lived with private respondent Florita A. Vallejo from 1970 to 1981, and they had two illegitimate children. On July 2, 1992, Vallejo filed a petition with the Regional Trial Court (RTC) of Cotabato City titled “Petition for Declaration of Heirship, Guardianship over the Persons and Properties of Minors Robert Rafson Alonzo and Rudyard Pride Alonzo, all surnamed Chua and Issuance of Letters of Administration.” She alleged that the minors were the sole heirs and sought appointment as guardian and administratrix. Petitioner Antonietta Garcia Vda. de Chua, claiming to be the surviving spouse of the decedent, filed a Motion to Dismiss on the ground of improper venue, asserting that Davao City was the decedent’s residence at the time of his death. Vallejo opposed, denying Antonietta’s status as wife and asserting the minors were Cotabato City residents. Vallejo also filed a Motion for Admission of an Amended Petition, changing the title to “In Re: Petition for the Settlement of the Intestate Estate of Roberto L. Chua, Declaration of Heirship, Guardianship over the Persons and Properties of Minors Robert and Rudyard, all surnamed Chua and Issuance of Letters of Administration,” and amending an allegation to state the decedent was a resident of Cotabato City. The RTC denied the motion to dismiss, finding Antonietta lacked personality to intervene as her marital status was unproven, and held Cotabato City was the proper venue. The RTC later granted the amended petition, declared the minors as sole heirs, appointed Vallejo as guardian and administratrix, and denied Antonietta’s subsequent motions. The Court of Appeals affirmed the RTC’s decision. Antonietta appealed to the Supreme Court via certiorari.

ISSUE

The primary issue is whether the Regional Trial Court of Cotabato City had jurisdiction over the settlement of the intestate estate of Roberto Lim Chua.

RULING

The Supreme Court denied the petition. It held that the RTC of Cotabato City properly acquired jurisdiction. The Court ruled that the amended petition, which was for the settlement of the intestate estate, declaration of heirship, and guardianship, was a permissible amendment as it did not substantially alter the cause of action but merely expanded the title to reflect the reliefs sought. Venue was properly laid in Cotabato City as the decedent was a resident there, supported by allegations in the amended petition and evidence such as property holdings. The Court found no denial of due process as petitioner was given opportunities to be heard on her motions. Furthermore, the Court distinguished the case from Gomez vs. Imperial, noting that the petition here was explicitly for both settlement of estate and guardianship, thus the lower court had jurisdiction to distribute the estate. The Court also held that petitioner’s proper remedy from the RTC orders was an ordinary appeal, not a special civil action for certiorari.