Manjoorsa, Krith Mounir, C.

Block B
ANCHETA v. GUERSEY-DALAYGON GR NO. 139868 (Rule 77)
Facts:
Spouses Audrey O’Neill (Audrey) and W. Richard Guersey (Richard) were American citizens
who have resided in the Philippines for 30 years. They have an adopted daughter, Kyle Guersey
Hill (Kyle). Audrey died in 1979. She left a will wherein she bequeathed her entire estate to
Richard consisting of Audrey’s conjugal share in real estate improvements at Forbes Park,
current account with cash balance and shares of stock in A/G Interiors. Two years after her
death, Richard married Candelaria Guersey-Dalaygon. Four years thereafter, Richard died and
left a will wherein he bequeathed his entire estate to respondent, except for his shares in A/G,
which he left to his adopted daughter. Petitioner, as ancillary administrator in the court where
Audrey’s will was admitted to probate, filed a motion to declare Richard and Kyle as heirs of
Audrey and a project of partition of Audrey’s estate. The motion and project of partition were
granted. Meanwhile, the ancillary administrator with regards to Richard’s will also filed a project
of partition, leaving 2/5 of Richard’s undivided interest in the Forbes property was allocated to
respondent Candelaria, while 3/5 thereof was allocated to their three children. Respondent
opposed on the ground that under the law of the State of Maryland, where Richard was a native
of, a legacy passes to the legatee the entire interest of the testator in the property subject to the
legacy.

Issue: Whether or not the decree of distribution may still be annulled under the circumstances.

Held:
A decree of distribution of the estate of a deceased person vests the title to the land of the
estate in the distributees, which, if erroneous may be corrected by a timely appeal. Once it
becomes final, its binding effect is like any other judgment in rem. However, in exceptional
cases, a final decree of distribution of the estate may be set aside for lack of jurisdiction or
fraud. Further, in Ramon vs. Ortuzar, the Court ruled that a party interested in a probate
proceeding may have a final liquidation set aside when he is left out by reason of circumstances
beyond his control or through mistake or inadvertence not imputable to negligence. Petitioner’s
failure to proficiently manage the distribution of Audrey’s estate according to the terms of her will
and as dictated by the applicable law amounted to extrinsic fraud. Hence the CA Decision
annulling the RTC Orders dated February 12, 1988 and April 7, 1988, must be upheld.