Raquiza v. Castellvi
REITERATIONFacts
The Antecedents: Appellants Jose and Consuelo Castellvi opposed the probate of the will of Don Alfonso de Castellvi, claiming to be acknowledged natural children and asserting the testator lacked a sound mind. The will designated Natividad Castellvi de Raquiza, the adopted daughter, as heir to two-thirds of the estate, with collateral relatives inheriting the remaining one-third. Procedural History: An agreement was approved on December 11, 1940, between Emilia A. Trono, guardian ad litem for the minor Mrs. Raquiza, and the appellants, acknowledging the appellants as acknowledged natural children and stipulating that Mrs. Raquiza would grant them half of her share if the will was enforced. The will was admitted to probate the same day. Trono later sought reconsideration, claiming lack of knowledge and authority, which was denied, with the court allegedly stating Mrs. Raquiza could annul the agreement upon reaching majority. Mrs. Raquiza, through her husband, moved to set aside the order and nullify the agreement, but this was denied due to finality. A subsequent civil case to nullify the agreement and order was dismissed without prejudice. Later, the administratrix moved to declare Mrs. Raquiza and collateral heirs as the sole heirs, excluding the appellants. The lower court, on November 11, 1959, denied the appellants' claim, deeming the agreement void ab initio and finding the appellants failed to prove their relationship. A prior Supreme Court decision (9 SCRA 395) affirmed this, declaring the appellants had no right to share or participate and that the compromise agreement was void under Article 1814 of the Civil Code of Spain. The Petition: Following the finality of the Supreme Court's decision, the appellants filed a "Petition de Senalamiento de Vista," requesting a new trial of the probate proceedings. They argued that because the compromise agreement was declared void, their opposition should be reinstated, and the will's probate should be set aside. The lower court denied this petition, leading to the present appeal.
Issue(s)
Whether the appellants, having voluntarily entered into a compromise agreement declared void by law, can still revive their opposition to the probate of the will after the agreement has been nullified. Whether the Supreme Court's prior decision, which declared appellants had no right to participate in the probate proceedings, precludes them from further intervention; and the inherent weakness of appellants' claim to be acknowledged natural children.
Ruling
The Supreme Court affirmed the order of the lower court denying the petition for a new trial. The Court held that appellants, having voluntarily entered into a compromise agreement declared void by law, could not recall or render ineffective what they had already done in performance of their part in the illegal bargain. Furthermore, a prior Supreme Court decision had already declared appellants as having no right to take part in the probate proceedings.
Ratio Decidendi
On the issue of reviving the opposition after a void compromise agreement: The Court ruled that appellants could not revive their opposition. It cited Article 1412 of the Civil Code, which states that when the fault is on the part of both contracting parties in an unlawful act that does not constitute a criminal offense, neither may recover what they have given by virtue of the contract, nor demand the performance of the other's undertaking. In this case, appellants withdrew their opposition based on the void agreement, and thus, they could not now ask that the approval of the will be set aside to reinstate their opposition. Their actions in compliance with the void agreement, such as allowing probate based on one witness, bound them. On the effect of the prior Supreme Court decision and the inherent weakness of appellants' claim: The Court reiterated its previous ruling in G.R. No. L-17630 (9 SCRA 395) which had already declared that appellants had "no right to take part" in the subject probate proceedings. This prior decision affirmed the lower court's order declaring that appellants had no right either to share in the estate or to take part in the case. Therefore, the present petition, which sought to allow them to intervene and prove their allegations, was effectively an attempt to reverse that final and executory decision, which the Court could not allow. The Court also noted, as it did in the previous decision, the inherent weakness of appellants' claim to be acknowledged natural children. The decedent's will explicitly mentioned his adopted daughter and his protegee, Amparo de Castellvi y Hortega, but made no mention of the appellants. Furthermore, the Civil Code of Spain (Article 131) required acknowledgment of a natural child to be made in a record of birth, a will, or some other public document, none of which the appellants could present to support their claim after the alleged father's death, except under specific circumstances not met here.
Main Doctrine
A compromise agreement declared void by law cannot be the basis for reviving a withdrawn opposition to a probate proceeding, as the parties are bound by their actions taken pursuant to the void agreement, especially when a prior Supreme Court decision has already declared them without right to participate in the proceedings.