Scribd Logo
Upload

Welcome to Scribd!

  • 2K views

    Ancheta vs. Guersey-Dalaygon (DIGEST)

    Uploaded by

    Samantha Nicole
    The Supreme Court ruled that: 1) Maryland law applies to the distribution of the estate of American citizen Audrey O'Neill since her will was probated in Maryland and she was domiciled in the US. 2) The petitioner, as ancillary administrator, committed extrinsic fraud by failing to distribute the estate according to Maryland law. His breach of fiduciary duty amounted to extrinsic fraud, preventing the respondent from fully presenting her side of the case. 3) The petitioner could not claim to distribute the estate according to Philippine law given that Audrey's will was probated in Maryland in 1982, making it clear she was a US citizen.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Ancheta vs. Guersey-Dalaygon (DIGEST)

    Uploaded by

    Samantha Nicole
    2K views2 pages
    The Supreme Court ruled that: 1) Maryland law applies to the distribution of the estate of American citizen Audrey O'Neill since her will was probated in Maryland and she was domiciled in the US. 2) The petitioner, as ancillary administrator, committed extrinsic fraud by failing to distribute the estate according to Maryland law. His breach of fiduciary duty amounted to extrinsic fraud, preventing the respondent from fully presenting her side of the case. 3) The petitioner could not claim to distribute the estate according to Philippine law given that Audrey's will was probated in Maryland in 1982, making it clear she was a US citizen.

    Original Description:

    Persons & Family Relations

    Original Title

    Ancheta vs. Guersey-Dalaygon [DIGEST]

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    The Supreme Court ruled that: 1) Maryland law applies to the distribution of the estate of American citizen Audrey O'Neill since her will was probated in Maryland and she was domiciled in the US. 2) The petitioner, as ancillary administrator, committed extrinsic fraud by failing to distribute the estate according to Maryland law. His breach of fiduciary duty amounted to extrinsic fraud, preventing the respondent from fully presenting her side of the case. 3) The petitioner could not claim to distribute the estate according to Philippine law given that Audrey's will was probated in Maryland in 1982, making it clear she was a US citizen.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views2 pages

    Ancheta vs. Guersey-Dalaygon (DIGEST)

    Uploaded by

    Samantha Nicole
    The Supreme Court ruled that: 1) Maryland law applies to the distribution of the estate of American citizen Audrey O'Neill since her will was probated in Maryland and she was domiciled in the US. 2) The petitioner, as ancillary administrator, committed extrinsic fraud by failing to distribute the estate according to Maryland law. His breach of fiduciary duty amounted to extrinsic fraud, preventing the respondent from fully presenting her side of the case. 3) The petitioner could not claim to distribute the estate according to Philippine law given that Audrey's will was probated in Maryland in 1982, making it clear she was a US citizen.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    You are on page 1of 2

    Ancheta, petitioner, vs.

    Guersey-Dalaygon, respondent
    G.R. No. 139868, June 8, 2006
    Austria-Martinez, J.

    Notes:
     Extrinsic fraud – fraudulent act committed outside trial of case that prevents defeated
    party from exhibiting his side fully
     1986 Constitution, Article XII, Sections 7-8 prohibits non-Filipinos from acquiring
    public and private domain

    Facts:
     American spouses Audrey O’Neill and W. Richard Guersey resided in Philippines for
    30 years with adopted daughter Kyle Guersey Hill
     Audrey’s will admitted to probate before Orphan’s Court of Baltimore and Court of
    First Instance of Rizal in Special Proceeding No. 9625
    o Bequeath entire estate to Richard
     Richard married Candelaria Guersey-Dalaygon in 1981
     Richard left will bequeathing entire estate to Guersey-Dalaygon and rights and
    interests over A/G Interiors, Inc. to Kyle
    o Admitted to probate in Oprhan’s Court of Ann Arundel, Maryland and
    Regional Trial Court of Makati in Special Proceeding No. M-888
     Ancillary administrator in Special Proceeding No. M-888 filed project of partition:
    o 2/5 of Richard’s ¾ undivided interest in Makati property allocated to Guersey-
    Dalaygon, 3/5 to Richard’s three children (Kyle, Kimberly, Kevin)
    o Opposed by respondent on grounds of Maryland law that all property subject
    of legacy is passed on to legatee
     Respondent contended petitioner willfully breached his fiduciary duty, amounting to
    extrinsic fraud
    o Petitioner contended he acted in good faith and had no knowledge of State of
    Maryland’s laws

    Issue:
    1. Whether or not the law of the State of Maryland is applicable to the acquiring of
    property in the Philippines
    2. Whether or not petitioner committed extrinsic fraud

    Ruling:
    1. YES; Maryland laws apply
    o Article 16 of Civil Code: national law of decedent is applicable; therefore
    petitioner should have distributed Audrey’s estate according to terms of her
    will
    o Last Will and Testament was probated before Orphans Court in Maryland
    o Audrey domiciled in the US – being foreign national, intrinsic validity is
    governed by her national law
    2. YES; petitioner’s breach of duty and fiduciary nature of petitioner combine to create a
    circumstance tantamount to extrinsic fraud
    o Failure to proficiently manage distribution dictated by applicable law
    amounted to extrinsic fraud
    o How can petitioner honestly presume Philippine laws apply when as early as
    reprobate of Audrey’s will before trial court in 1982, already brought to fore
    that Audrey was a US citizen

    You might also like