G.R. No. 108581.
December 08, 1999 (Case Brief / Digest)
### Title:
**Lourdes L. Dorotheo vs. Court of Appeals and Nilda D. Quintana et al.: A Question on the
Validity and Effect of a Will**
### Facts:
The case commenced following the death of Alejandro Dorotheo, whose estate remained
unsettled after his spouse, Aniceta Reyes, died in 1969. In 1977, Lourdes L. Dorotheo,
alleging to have cared for Alejandro before his death, filed a special proceeding for the
probate of Alejandro’s last will and testament. The will was admitted to probate in 1981
without an appeal from Alejandro’s legitimate children, Nilda D. Quintana, Vicente
Dorotheo, and Jose Dorotheo (private respondents). However, in 1983, they moved to
declare the will intrinsically void, which the trial court granted in 1986.
Lourdes'[petitioner’s] subsequent appeal to the Court of Appeals was dismissed for failure
to submit her brief on time. This dismissal was final and executory by 1989.
Despite an executory order stating the intrinsic voidness of the will and the distribution of
the estate according to intestate laws, Lourdes opposed the motions filed by private
respondents to surrender the Transfer Certificates of Titles (TCTs) she held. This led to
further legal battles, culminating in the trial court’s controversial orders in 1990 and 1991,
attempting to set aside the final and executory order on the will’s intrinsic invalidity. The
Court of Appeals nullified these orders, prompting Lourdes to elevate the matter to the
Supreme Court.
### Issues:
1. Can a probated will, declared intrinsically void in a final and executory order, still be
given effect?
2. Is a lower court allowed to set aside its final and executory orders based on its
interpretation of interlocutory orders?
3. Does the finality of a decision or order preclude its reconsideration on the grounds of
perceived errors?
### Court’s Decision:
The Philippine Supreme Court held that a final and executory decision or order is immutable
and cannot be altered, regardless of its perceived erroneous nature. The High Court
emphasized that the orders setting aside the final and executory order on the intrinsic
invalidity of Alejandro’s will were issued in error, infringing on the principle of finality of
judgments. The Court further clarified that probate proceedings deal with the extrinsic
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G.R. No. 108581. December 08, 1999 (Case Brief / Digest)
validity of the will, and questions about its intrinsic validity could still be raised even after
authentication. Thus, despite the extrinsic validity of Alejandro’s will, its intrinsic provisions
were correctly adjudged void, necessitating the application of intestate succession laws. The
Supreme Court denied Lourdes’ petition, affirming the appellate court’s decision.
### Doctrine:
The doctrine established in this case reaffirms the principle that a final and executory
decision by the court is unalterable and binds the parties, ensuring finality in legal
proceedings. It distinguishes between the extrinsic and intrinsic validity of wills,
underscoring that while a will may be extrinsically valid, its intrinsic provisions can still be
contested and declared void if they violate laws on succession and the legitimate heirs’
rights.
### Class Notes:
– Final and Executory Decisions: Once a decision or order becomes final and executory, it is
immune from alteration. Failure to appeal within the prescribed period leads to finality.
– Extrinsic vs. Intrinsic Validity: Extrinsic validity concerns the formalities and due
execution of the will, while intrinsic validity pertains to the content, disposition, and
compliance with the laws on succession.
– Intestate Succession as Default: In cases where a will is deemed extrinsically valid but
found intrinsically void, the distribution of the estate follows the laws of intestate
succession.
– The doctrine of “Res Judicata”: Matters that have been adjudicated by a competent court
and have reached finality cannot again be brought into question in any future lawsuit.
### Historical Background:
This case highlights the complexities of succession law in the Philippines, illustrating the
nuances between the extrinsic and intrinsic validity of wills. It underscores the judiciary’s
role in interpreting and enforcing succession laws, balancing the decedent’s testamentary
intentions with statutory provisions protecting compulsory heirs. It also emphasizes the
legal system’s emphasis on the finality of judgments as a means to ensure certainty and
prevent protracted litigation.
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