‘CECILIO G. HERNANDEZ, MA. VICTORIA C. HERNANDEZ-SAGUN, "GR No. 166470 TERESA C. HERNANDEZ-VILLA ABRILLE ond NATIVIDAD CRUZHERNANDEZ, [Dale: August 7, 2007 Petitioners vs. JOVITA SAN JUAN-SANTOS, Respondent Ponente: Corona. J ‘An oxcinary winess may give tis opinion on the mental sarity of @ person with whom he is cuficiently acquainted (S2>. 59, Ruls 130). Where the sarity of a person is ative. expert opinicn is not necessary. The observations of the tal juage coupled with evidence ertabiching the person's state of mental sanity wi suffice. FACTS + ab 141847 - Wario Lourdes San Juan Hemandes (or Lulu) was bom fo the spoures Fel: Hemandez ond Mario San Juan 4emandez Mara died due to complections dung cnidbrth ‘After Marios death. Felix ef Lulu in the care of her maternal uncle, Sotero C. San Juan. + Dec 16 1951 - Felix married Notividad Cruz. The Union produced three children, petitioners herein Meanwhile, as the only child of Maria and the sole testate heir of Sotero, Llu inherited valudole: real properties from the San Juan farriy (conservatively estimated at PED rilion in 1997}. ‘+ Sometime in 1957 - Luly went to live with her father and ris new family. Due to her ‘violent ‘personally, Lulu stopped schooling when she reached Grade 5. ‘+ 1988- Upon reacring ine oge of majenty, Luly was glven Tul Control of ner estate. Nevertnetess, ‘because Lulu cid not even firsh her elementary education, Felix continued to exercise actual ‘aminisiraton of Lu propertes, ‘+ 1993-Upon Felkxs death, petitioners took over the task of adiministering Luis properties. ‘+1868 10 1999 Felix and pettiones undertock various projects inveving Luly'sreal propetios ‘+ 1995~ Luu was made to sign an SPA believing she was authorizng her halister to appear in ‘Seut wher told that hor 11-hectare propery in Rizal was urder Figation, when in truth, che war in fact unknowiraly authoring her fo sell it His half-brother also asked Lulu to authorize him to leace her 4Shectare propery in Pizal ss that “Lully could have o ear an clever” ‘+1998 -Lulu sought the assistance of her maternal rst cousin, respondent Joviia San Juan-Santos, ‘ter leering that patiioner: had been disinating her actate. She conficied to lovita that she: was made fo ive in the basement of petifioners’ Montalban, Rizal home and was receiving a measy daly allowance of P400 for her food and medication. Lulu was severely overweight. unkempt ond smelled of utine. Due to Lulus poor hygiene, respondent brought her to several ‘Shysicians for medical examination. Luu wos found fo be afficted with tuberculoss, cheumatsm {and diabetes from wrich she was suffering several complications. ‘+ San Jan family demanded of an inventory and accounting of Lulu’ estate from petitioners Which demand was ignored. Respondent then filed fora Pettion ot Guardianship. ‘+ Medical specialsts testified 10 explain the resus of Lui’s examinations which revealed the Glarming sate of her Neath. Furthemore, they unarimeusly opined that in view of Luvs inteligence level {which was below average) and fragle mental sate, she would not be able fo Core for herseif and seltasminser Fer medications. Luk was aso presented and asked 10 testy, + RIC = Due te her weak physical and mental conditien, there was a need to appcin' a legal guardian over the person and property of Lulu. Thus, it declared Lulu an incompetent and ppcintedrespendient at guaraian ver the persion and praperty of Luly on aP1 milion bend. © CA-Mtimedintoto. © November 2003 - Luly was abducted from her Marikina apartment. Pefiners suesequenty contacted the PACER (poice) fo inform them that Luu voluntoriy left wth Natividad because her guarcian had allegedly been mattreatira her ‘+ Respondent filed a petifion for habeas cores in the CA alleging that petitioners abducted Lulu fond were holding her captive in an undisclosed location in Rodtiguez, Rizal. CA granted the petition. ‘+ Pefitioners claim that the opinions of Lulu’ cttencing physicians regarding her mental state were: inacinissiblein evidence os they were not expertsin psycriaty. ISsuES Weiner or nof the opinion of luis affencing physicians regarding ner mental date where incgmissie Inevidence os they were not exoers in psychiatry? ~ They are admissible. ‘+ Under Section 50, Rule 130 of the Rules of Court. on ordinary wiiness may aive his coinion on the:‘mental sanily of a person with whom he is sulfciently aequairfed. Luls attending physicians ‘spoke ond interacted witn her. Such occasions allowed themto thoroughly observe her ‘behavior and conciude that her inteligence level was below average and her mental stage ‘below normal. Their opinions were admissible in evidence. Furthermore, where the sarity of a person is at issue, expert opinion is not necessary. The ‘observations ofthe trial judge coupled with evidence establishing the person's state of mental sarity wil suffice. Here, the trial judge was given ample opporunity to observe Lulu personally when she tesiied before the RTC. Pefitioners are furthermore ordered to render to respondent, Luly legal guardian, an accurate {and faithful accounting cf all the properties and funds they unlawfully appropriated for ‘themselves from the estate of Mavia Lourdes San Juan Hemardez, within thirty (80) days from receipt of this decision. If warranted, the proper complaints should also be Cled against them for ‘any criminal iabity in connection with the dissipation of Maria Lourdes San Juan Hernander’s [estate and her unlawful cbduction from the custody of her leaal avardian.