Cayetano vs. Leonidas

The intrinsic validity of testamentary provisions, including the order of succession and the amount of successional rights, is governed exclusively by the national law of the decedent pursuant to Article 16, paragraph 2 of the Civil Code; consequently, Philippine laws on legitimes do not apply to the estate of a foreign national whose own national law does not provide for such compulsory inheritance.

Adoracion C. Campos was an American citizen and a permanent resident of Philadelphia, Pennsylvania, who died in Manila in 1977 while on a temporary visit. Her father, Hermogenes Campos, initially took possession of her entire estate by executing an Affidavit of Adjudication, claiming to be her sole compulsory heir. However, a will executed by Adoracion in the United States, which had already been probated in Pennsylvania, was later presented for reprobate in the Philippines by her sister, Nenita Campos Paguia.

• Adoracion C. Campos, a citizen of the United States and resident of Pennsylvania, died in Manila on January 31, 1977.
• Her father, Hermogenes Campos, adjudicated the entire estate to himself via an Affidavit of Adjudication under Rule 74, Section 1.
• Nenita Campos Paguia filed for the reprobate of Adoracion's Pennsylvania-probated will in the Court of First Instance (CFI) of Manila.
• Hermogenes initially opposed the reprobate, claiming the will was a forgery and that its provisions were null and void for violating his rights as a compulsory heir.
• Hermogenes later withdrew his opposition through a motion and a subsequent manifestation, stating he had verified the veracity of the will.
• Following the withdrawal, the CFI Manila admitted the will to probate and appointed Nenita as the administratrix.
• Hermogenes subsequently filed a petition for relief, claiming his withdrawal was obtained through fraud and that the lawyer who filed it was not his counsel of record.
• Hermogenes also filed a motion to vacate the probate order, arguing the CFI Manila lacked jurisdiction because Adoracion was allegedly a resident of Cavite.
• The trial court dismissed the petition for relief and the motion to vacate after Hermogenes failed to present evidence during the scheduled hearings.
• Hermogenes died during the pendency of the case and was substituted by Polly Cayetano, who continued the legal challenge.

• The respondent judge committed grave abuse of discretion by allowing the withdrawal of the opposition, which was allegedly secured through fraudulent means.
• The petitioner was deprived of due process because the trial court denied the petition for relief without a proper hearing on the merits of the motion to vacate.
• The CFI Manila lacked jurisdiction over the estate because the decedent was a resident of Cavite, not a foreign resident.
• The will is intrinsically void under Philippine law because it preterited the father, who is a compulsory heir entitled to a legitime.
• The national law of the decedent (Pennsylvania) should not apply if it works an injustice or injury to a citizen of the Philippines.

• The withdrawal of the opposition was a voluntary act of the petitioner, as evidenced by his own signed manifestation filed after the motion to dismiss the opposition.
• The decedent was a proven American citizen and resident of Pennsylvania, making the Manila court the proper venue for the settlement of her estate located in the Philippines.
• Under Articles 16 and 1039 of the Civil Code, the national law of the decedent governs the intrinsic validity of the will and the capacity to succeed.
• Pennsylvania law does not provide for legitimes or forced heirs; therefore, the testatrix was free to dispose of her estate as she pleased.
• The petitioner is estopped from questioning the jurisdiction of the probate court after having participated in the proceedings and seeking relief therein.

• Procedural Issues:
  • Whether the respondent judge acted with grave abuse of discretion in admitting the will to probate following the withdrawal of the petitioner's opposition.
  • Whether the Court of First Instance of Manila had proper jurisdiction over the reprobate of the will.
• Substantive Issues:
  • Whether the intrinsic validity of the will and the successional rights of the heirs are governed by Philippine law or the national law of the decedent.

• Procedural:
  • The Court held there was no grave abuse of discretion because the petitioner failed to provide proof that his withdrawal of opposition was fraudulent, and the records showed he explicitly confirmed the withdrawal in a later manifestation.
  • The Court ruled that the CFI Manila had jurisdiction under Rule 73, Section 1, because the decedent was a non-resident with property in Manila, and the petitioner was estopped from challenging jurisdiction after failing to obtain the relief he sought from that same court.
• Substantive:
  • The Court ruled that the intrinsic validity of the will is governed by the national law of the decedent (Pennsylvania) pursuant to Article 16(2) and Article 1039 of the Civil Code.
  • The Court affirmed that since Pennsylvania law does not recognize legitimes, the will is valid even if it excludes the father, as Philippine public policy regarding compulsory heirs does not apply to the succession of foreign nationals.

• Lex Nationalii (Article 16, Civil Code) — This doctrine provides that the national law of the decedent governs the order of succession, the amount of successional rights, and the intrinsic validity of testamentary provisions; in this case, it established that Pennsylvania law, not Philippine law, determined the validity of the distribution of the estate.
• Estoppel in Jurisdiction — This principle prevents a party from invoking a court's jurisdiction to secure relief and then later repudiating that same jurisdiction after failing to obtain a favorable outcome.
• Intrinsic Validity in Probate — While probate is generally limited to extrinsic validity (due execution), a court may pass upon the intrinsic validity of a will before probate when practical considerations or the face of the will demand it, such as when the decedent's national law clearly precludes the application of Philippine legitimes.

• "It is therefore evident that whatever public policy or good customs may be involved in our system of legitimes, Congress has not intended to extend the same to the succession of foreign nationals."

• Bellis v. Bellis (20 SCRA 358) — This case was cited as the controlling precedent to prove that the national law of a foreign decedent must prevail over Philippine laws on legitimes, regardless of any perceived conflict with local public policy.
• Maninang v. Court of Appeals (114 SCRA 478) — Referenced to explain that while probate courts usually focus on extrinsic validity, they may address intrinsic validity when practical considerations require it.
• Saulog Transit, Inc. v. Hon. Manuel Lazaro (G.R. No. 63284) — Cited to support the rule that a party cannot contest the jurisdiction of a court after having voluntarily submitted to it and failing to get relief.
• De Borja vs. Tan (G.R. No. L-7792) — Cited by the petitioner to argue regarding jurisdiction but distinguished by the court based on the decedent's actual residence and citizenship.

• Article 16, paragraph 2, Civil Code — Mandates that the national law of the decedent regulates the order of succession, the amount of successional rights, and the intrinsic validity of testamentary provisions.
• Article 1039, Civil Code — Provides that the capacity to succeed is governed by the national law of the decedent.
• Rule 73, Section 1, Rules of Court — Establishes the venue for the settlement of estates, providing that for non-residents, the court of any province where they had an estate shall have jurisdiction.
• Rule 74, Section 1, Rules of Court — Relates to the summary settlement of estates, which the petitioner initially attempted to use to adjudicate the estate to himself.