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