RULE 77

ANCHETA V. GUERSEY-DALAYGON (Succession)

Binding Effect of Judgments
490 SCRA 140, June 8, 2006

Facts:

Spouses Audrey ONeill (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 Audreys
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 Audreys will was admitted to probate, filed a
motion to declare Richard and Kyle as heirs of Audrey and a project of partition of Audreys estate. The
motion and project of partition were granted. Meanwhile, the ancillary administrator with regards to
Richards will also filed a project of partition, leaving 2/5 of Richards 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.

Petitioners failure to proficiently manage the distribution of Audreys 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.
RULE 78