G.R. No. L-7019; May 31, 1955
In the matter of the intestate estate of the deceased Rosalia Saquitan. EULOGIO S. EUSEBIO, administrator-appellee, vs. DOMINGO VALMORES, oppositor-appellant deceased. JACINTA SISCAR, widow of deceased, oppositor-appellant.

FACTS

On July 31, 1952, Francisco Valmores (real name Francisco Delmindo) filed a petition for the settlement of the intestate estate of Rosalia Saquitan, who died on October 1, 1950. He claimed to be the adopted son of the spouses Domingo Valmores (the surviving husband) and Rosalia Saquitan, and recommended the appointment of Eulogio Eusebio as administrator, alleging Domingo was over 80 and unfit. The court set a hearing for August 29, 1952, with notice published in “La Opinion.” At the hearing, only the petitioner’s counsel appeared; Francisco Valmores did not. Counsel presented Raymundo Delmindo (Francisco’s brother), who testified to the adoption and Domingo’s incapacity, and noted Domingo had filed an affidavit adjudicating the estate to himself under Rule 74. The court immediately appointed Eulogio Eusebio as administrator. Subsequent proceedings progressed rapidly: oath and bond (September 3), letters of administration (September 5), notice to creditors (September 6), inventory (November 29), supplemental inventory (March 6, 1953), final accounts and project of partition (March 17, 1953). On March 23, 1953, Domingo Valmores filed an opposition, challenging Eusebio’s appointment as a stranger and seeking his own appointment, requesting a hearing to present evidence. This was denied, and his motion for reconsideration was also denied on May 14, 1953. Domingo appealed. During the appeal, Domingo died on May 13, 1954, and his widow, Jacinta Siscar, was substituted. Later, Maximo Saquitan, claiming to be Rosalia’s nephew and nearest heir, petitioned the Supreme Court, alleging Francisco Delmindo fraudulently filed the petition, that notice was not given to him, and that “La Opinion” was not a newspaper of general circulation in Rizal.

ISSUE

Whether the proceedings for the settlement of the intestate estate of Rosalia Saquitan are valid, considering alleged defects in the petitioner’s interest, lack of proper notice to known heirs, and irregularities in the appointment of the administrator.

RULING

The Supreme Court annulled all proceedings subsequent to the petition and remanded the case to the court of origin for a new hearing. The Court found fatal irregularities: (1) The petitioner, Francisco Delmindo, failed to prove he was a legally adopted son and thus an “interested person” as required by Rule 80, Section 2. The only evidence was his brother’s testimony, with no court records of adoption presented, and the Local Civil Registrar certified no record of such adoption existed. However, this defect was considered cured by Domingo Valmores’s act of opposing the appointment (but not the petition itself), thereby ratifying the proceedings. (2) The mandatory notice requirements under Rules 77 and 80 were not complied with. There was no evidence that Domingo Valmores, the known heir, or Maximo Saquitan, another heir, received personal notice of the hearing as required. The absence of such notice deprived them of due process. (3) The trial court failed to exercise proper care in evaluating the evidence and following procedural rules, contributing to the irregularities. The case was remanded for a hearing on the original petition and Domingo’s opposition, with proper notice to all interested parties, including Jacinta Siscar and Maximo Saquitan.