Reyes v Sotero, GR 167405

Nature: Petition for review on the decision of the CA which annulled the decision of
the RTC

Facts: Chichioco filed a petition for administration and settlement of Lising’s estate.
According to her, the decedent left real properties and personal properties in the
hands of her grandniece Reyes.

Reyes opposed the petition stating that she was an adopted child of Lising. She
asserted that the petition be dismissed and that the appointment would be
unnecessary because she was the only heir of Lising.

Issue: Whether the CA erred n holding that petitioner had to prove the validity of her
adoption due to imputation of irregularities

Ruling: Yes, the CA erred in their ruling.

Ruling:An adoption decree is a public document required by law to be entered into

records, the official repository of which is the local civil registrars office as well as the
court which rendered the judgment.

Contrary proof can only be ascertained in a separate action brought principally for the
purpose of nullifying the adoption decree. The latter cannot be assailed collaterally
in a proceeding for the settlement of an estate.
Heirs of Doronio, GR 169454

Nature: Review on Certiorari of the decision of the CA reversing the decision of the
RTC. The CA ruled in favor of the heirs of Fortunato Doronio

Facts: Spouses Simeon and Cornelia Doronio had children but records failed to show
their number. It was made clear however that among their children were Marcelino
and Fortunato. The parties in this case are their heirs. A private deed of donation
propetr nuptias was executed by the spouses in favor of Marcelino, including a
property covered by OCT 352 which was described as a residential land occupied on
the east by Fortunato Doronio.

Both parties have been occupying the subject land for several decades although they
have different theories regarding its present ownership. Petitioners claim that they
are the owners by virtue of the donation propter nuptias. Respondents claim that
only half of the property was incorporated in the said deed of donation.
Respondents posit that the donors respected and segregated the possession of
Fotunato on the eastern half of the land.

Eager to obtain the entire property, the heirs of Marcelino filed a petition for
refistration of a private deed of donation. During the hearings, no one objected to
the petition. The RTC ordered a general default and the petition was granted.

The hears of Fortunato filed a pleading before RTC for reconsideration of the decision.
The petition was dismissed because it was not filed on time. Aggrieved, they filed an
action for reconveyance.

The RTC ruled in favor of the heirs of Marcelino stating that the parties admitted the
identity of the land which they occupy and that the heirs of Fortunato are not the
rightful owners of the property.

The heirs of Fortunato appealed to the CA arguing that the trial court erred in not
finding that respondents predecessors-in-interest aquired one-half of the property.

The CA reversed the decision of the RTC stating that the donation of the entire
property to Marcelino is invalid on the ground that that it impairs the legitime of
Fortunato. Hence, this petition.
Issue: Whether the CA erred in ruling that only half of the disputed property was
donated to the predecessors-in-interest of the appellants, heirs of Marcelino Doronio

Ruling: Issues on impairment of legitime should be threshed out in a special

proceeding, not in civil action for reconveyance and damages

Petitioners are correct in alleging that the issue regarding the impairment of legitime
of Fortunato Doronio must be resolved in an action for the settlement of estates of
Simeon and Cornelia. It may not be passed in an action for reconveyance and
damages. A probate court is the best forum to ventilate and adjudge the issue of
impairment of legitime as well as other related matters involving the settlement of
estate.

An action for reconveyance with damages is a civil action, whereas matters relating to
the settlement of the estate of a deceased person such as advancement of property
made by the decedent, is a special proceeding. Special proceedings require the
application of specific rules provided in the Rules of Court.