Ancheta v.

Candelaria

The case of Alonzo Ancheta v. Candelaria Guersey-Dalaygon involves American spouses Audrey and
Richard who have resided In the Philippines for 30 years. They have an adopted daughter named Kyle.
Audrey died and left a will where she left her entire estate consisting of her conjugal share in real estate
in Forbes Park, a bank account, cash balance and shares of stock in A/G Interiors to her husband Richard.
Two years later, Richard married Candelaria with whom he had two children named Kimberly and Kevin.
Four years thereafter, Richard died and left a will wherein he bequeathed his entire estate to Candelaria,
except for his shares in A/G, which he left to his adopted daughter. Audrey’s will was admitted to
probate. Inventory was taken on their conjugal properties. Ancheta, as the administrator, filed for a
partition of the first wife’s estate. The will was also admitted in a court in Maryland. Ancheta 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, Atty. Quasha, the ancillary administrator,
with regards to Richard’s will, also filed a project of partition, leaving 2/5 of Richard’s 3/4 undivided
interest in the Makati property was allocated to Candelaria, while 3/5 thereof was allocated to their
three children. Candelaria 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.

The trial court disapproved the project of partition as to the Makati property and adjudicated Richard's
entire ¾ undivided interest in the Makati property to Candelaria.

Candelaria contends that Ancheta willfully breached his fiduciary duty when he disregarded the laws of
the State of Maryland on the distribution of Audrey's estate in accordance with her will. Candelaria
further argued that since Audrey devised her entire estate to Richard, then the Makati property should
be wholly adjudicated to him, and not merely 3/4 thereof, and since Richard left his entire estate, except
for his rights and interests over the A/G Interiors, Inc., to Candelaria, then the entire Makati property
should now pertain to Candelaria.

Ancheta contends that that he acted in good faith in performing his duties as an ancillary administrator.
He maintains that at the time of the filing of the project of partition, he was not aware of the relevant
laws of the State of Maryland, such that the partition was made in accordance with Philippine laws.

The CA annulled the trial court’s orders and adjudicated the entire estate of Audrey in favor of the
estate of Richard.

Issue: Whether or not the Court of Appeals is correct in adjudicating the entire estate of Audrey in favor
of the estate of Richard.

Ruling: Yes. Being a foreign national, the intrinsic validity of Audrey's will, especially with regard as to
who are her heirs, is governed by her national law—the law of the State of Maryland, as provided in
Article 16 of the Civil Code. Article 16 of the Civil Code states that as a general rule, real property as well
as personal property is subject to the law of the country where it is situated. Except in cases of intestate
and testamentary succession, with respect to the order of succession and to the amount of successional
rights and to the intrinsic validity of testamentary provisions, where it shall be regulated by the national
law of the person whose succession is under consideration, whatever may be the nature of the property
and regardless of the country wherein said property may be found.

In addition, Rule 77, Section 4 of the Rules of Court provides that, such estate, after the payment of just
debts and expenses of administration, shall be disposed of according to such will, so far as such will may
operate upon it.

The Supreme Court added that while foreign laws do not prove themselves in our jurisdiction and our
courts are not authorized to take judicial notice of them, Ancheta, as ancillary administrator of Audrey's
estate, was duty-bound to introduce in evidence the pertinent law of the State of Maryland.

Petitioner admitted that he failed to introduce in evidence the law of the State of Maryland on Estates
and Trusts, and merely relied on the presumption that such law is the same as the Philippine law on wills
and succession. Thus, the trial court peremptorily applied Philippine laws and totally disregarded the
terms of Audrey’s will. The obvious result was that there was no fair submission of the case before the
trial court or a judicious appreciation of the evidence presented.