Rivera v Ramirez
G.R. No. 189697, June 27, 2012
FACTS:
Spouses Adolfo Ramirez and Rosita Rivera were married in 1942. Their only child died in infancy. They acquired during their lifetime the Sta. Teresita General Hospital and other properties. Rosita died in September 1990, followed by her husband Adolfo in December 1993. On February 7, 1995 petitioner Eleuterio P. Rivera filed a petition for issuance of letters of administration claiming that he was Rosita’s nephew, being the son of her brother Federico. On April 18, 1996 he filed in his capacity as administrator a motion with the court to compel the examination and production of documents relating to properties believed to be a part of Rosita’s estate, foremost of which was the Sta. Teresita General Hospital that respondent Robert Ramirez had been managing.Robert claimed, together with Raymond Ramirez and Lydia Ramirez, that they were children of Adolfo by another woman.
The Court of Appeals eventually ruled that Eleuterio and Rosita’s other collateral relatives were not her heirs since she had an adopted child in Raymond and that, consequently, Eleuterio and all others 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 Raymond was Rosita’s adopted child
RULING:
No. Whether or not the late Rosita had judicially adopted Raymond as her child was stated by the Court to be a question of fact that had neither been 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. One of the reasons Robert brought the special civil action of certiorari before the CA was that Eleuterio had no right to inspect the requested documents and have access to Adolfo’s estate when Eleuterio’s authority as administrator extended only to Rosita’s estate. The Court recognized the CA’s commendable desire to minimize multiple appeals. But the issues 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 were never raised and properly tried before the RTC. Consequently, the CA gravely abused its discretion in adjudicating such issues and denying Eleuterio and his relatives their right to be heard on them.
