Eleuterio Rivera v. Robert Ramirez and Raymond Ramirez
G.R. No. 189697, June 27, 2012
FACTS:
Spouses Adolfo Ramirez and Rosita Rivera have acquired during their lifetime the Sta. Teresita General Hospital and other properties. In September 1990 and December 1993, Rosita and Adolfo died, respectively. Petitioner Eleuterio Rivera, Rosita’s nephew, was appointed by the RTC as administrator of Rosita’s estate. Subsequently, in his capacity as such, he filed a motion with the court to compel the examination and production of documents relating to properties believed to be part of Rosita’s estate, foremost of which was the Sta. Teresita General Hospital that respondent Robert Ramirez (Robert) had been managing. Robert claimed, together with Raymond Ramirez (Raymond) and Lydia Ramirez (Lydia), that they were children of Adolfo by another woman. Robert opposed the issuance of the subpoena.
The RTC granted the administrator’s motion and ordered Roert to bring to the court the documents relating to the operations of the hospital property. The case was elevated to the Court of Appeals, which annulled the orders of the RTC. Essentially, the CA held that Eleuterio and Rosita’s other collateral relatives were not her heirs since she had an adopted child in Raymond and that, consequently, Eleuterio, et al. had no standing to request production of the hospital’s documents or to institute the petition for the settlement of her estate.
ISSUE:
Whether or not Eleuterio had no standing to request production of the hospital’s documents or to institute the petition for the settlement of Rosita’s estate considering the presence of an adopted child.
RULING:
No. The Supreme Court ruled that the CA erred in passing upon the issue regarding the late Rosita’s supposed judicial adoption of Raymond as her child and the consequent absence of right on the part of Eleuterio, et. al. to file a petition for the settlement of Rosita’s estate. Firstly, the issue was neither considered nor passed upon by the RTC in a direct challenge to the claim of Eleuterio and Rosita’s other collateral relatives that they have the right to inherit from her. The relevant issue before the RTC was only whether or not the duly appointed administrator of Rosita’s estate had the right to the production and examination of the documents believed to be in Robert’s possession. Thus, the CA gravely abused its discretion in adjudicating such issues and denying Eleuterio and his relatives their right to be heard on them. The petition was granted.
