Scribd
Upload
521 views2 pages

(B5) LAW 100 - Ancheta Vs Guersey-Dalaygon (G.R. No. 139868)

This case involved the estate of Audrey O'Neil, an American citizen who resided in the Philippines and left her entire estate to her husband Richard upon her death. Richard later remarried Candelaria and also left his entire estate to her when he died. However, the court-appointed administrator Alonzo Ancheta divided Audrey's estate between Richard and their adopted daughter upon Richard's death. Candelaria filed a complaint to annul this, arguing Ancheta disregarded Audrey's will leaving everything to Richard. The Court of Appeals ruled in Candelaria's favor, finding Ancheta committed extrinsic fraud by not following the law of Audrey's state regarding inheritance in wills.

Uploaded by

m
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
521 views2 pages

(B5) LAW 100 - Ancheta Vs Guersey-Dalaygon (G.R. No. 139868)

This case involved the estate of Audrey O'Neil, an American citizen who resided in the Philippines and left her entire estate to her husband Richard upon her death. Richard later remarried Candelaria and also left his entire estate to her when he died. However, the court-appointed administrator Alonzo Ancheta divided Audrey's estate between Richard and their adopted daughter upon Richard's death. Candelaria filed a complaint to annul this, arguing Ancheta disregarded Audrey's will leaving everything to Richard. The Court of Appeals ruled in Candelaria's favor, finding Ancheta committed extrinsic fraud by not following the law of Audrey's state regarding inheritance in wills.

Uploaded by

m
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Alonzo Q. Ancheta vs.

Candelaria Guersey-Dalaygon
G.R. No. 139868
June 8, 2006
Austria-Martinez, Ma. Alicia, J.

SUBJECT MATTER:
Introduction to Civil Law

ACTION BEFORE THE SUPREME COURT:


Petition for Certiorari

Petitioner(s): Atty. Alonzo Q. Anchetta


Parties
Respondent(s): Candelaria Guersey-Dalayagon

SUMMARY:
The couple Audrey O’Neil and W. Richard Guersey were American Citizens residing in the Philippines. Audrey passed away, leaving
her entire estate to her husband, Richard. Richard then passed away, leaving his entire estate to his second wife, Candelaria
Guersey-Dalaygon (Respondent). Atty. Alonzo Q. Anchetta served as ancillary administrator to Audrey’s will; he then divided her
estate, via a project for partition, between Richard and their adopted daughter, Kyle Guersey Hill. Respondent filed a complaint for
annulment at the Court of Appeals, arguing that the Petitioner did not follow Audrey’s will, in which she left her entire estate to
Richard, not Richard and their adopted daughter. Court of Appeal granted the petition; the project of partition was annulled.

ANTECEDENT FACTS:

● Spouses Audrey O’Neil and W. Richard Guersey were American Citizens who have resided in the Philippines for 30 years.
They have an adopted daughter, Kyle Guersey Hill.
● On July 29, 1979, Audrey died, leaving her entire estate to Richard. Atty. Alonzo Anchetta (Petitioner) as ancillary
administrator.
● In 1981, Richard married Candelaria Guersey-Dalaygon (Respondent) with whom he has two children, namely, Kimberly and
Kevin.
● On July 20, 1984, Richard died, leaving his entire estate to the Respondent.
● On Oct 19, 1987, Petitioner filed a project of partition of Audrey’s estate, dividing her estate between Richard and their
adopted daughter Kyle. The petition was granted by trial court on Feb 12, 1988.
● On Apr 7, 1988, the trial court issued an order that the estate of Richard now be titled the Estate of W. Richard Guersey
(3/4 undivided interest) and Kyle (1/4) undivided interest.
● On Oct 20, 1993, Respondent filed at the Court of Appeals a complaint for annulment on orders dated Feb 12, 1988 and Apr
7, 1988. Respondent argues that the Petitioner disregarded the laws of the State of Maryland, from which Audrey was a
citizen of. Thus, the Petitioner committed extrinsic fraud.
● On Mar 18, 1999, the Court of Appeals granted the annulment.

ISSUE(S) AND HOLDING(S):

1. W/N petitioner acted in good faith, not committing either extrinsic or intrinsic fraud. -- NO
2. W/N annulment on orders dated Feb 12, 1988 and Apr 7, 1988 is not valid. -- NO

RATIO:

C2023(MARTIN) - Persons and Family Relations, Aguiling-Pangalangan


1. Petitioner did not act in good faith and committed extrinsic fraud. The Petitioner, whether by accident or on purpose,
disregarded the law of the State of Maryland, which states that “a legacy passes to the legatee the entire interest of the
testator in the property subject of the legacy.”
○ The Petitioner divided the estate, under the belief that Philippine law applied. The Petitioner also expressed that
he believed that dividing the estate would benefit Kyle. However, it was not for the Petitioner to act on Kyle’s
behalf, but rather on the will of Audrey. Audrey’s will stated that her entire estate be left to Richard, which the
Petitioner failed to follow.
2. The annulment on orders dated Feb 12, 1988 and Apr 7, 1988 is still valid. The petition for annulment was filed before the
issuance of the 1997 Rules of Civil Procedure. Thus, the applicable law is Batas Pambansa Blg. 129.
○ An annulment of judgement under B.P. 129 may be based on the grounds that judgement lacks jurisdiction or was
obtained by extrinsic fraud. As the court has already ruled that the Petitioner committed extrinsic fraud, the
annulment holds.

DISPOSITIVE:
The petition is DENIED. Petitioner is ADMONISHED to be more circumspect in the performance of his duties as an official of the
court. No pronouncement as to costs.

C2023(MARTIN) - Persons and Family Relations, Aguiling-Pangalangan

You might also like