Pavicevic v. Iannarelli

Pavicevic v. Iannarelli

The trial judge correctly applied the presumption of death and the statutory test in s.2(4) of the Declarations of Death Act, finding sufficient evidence that the missing person had been unaccounted for for more than seven years and declaring death as of January 10, 1997; because the parties held title as joint...

Source-derived case information.

Citation
2008 ONCA 865
Parties
Appellant: Jasminka Pavicevic; Appellant: Jeromy Predrag Pavicevic; Respondent: Betty Iannarelli
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
23 December 2008
Procedural Posture
Civil Appeal / Decision on Appeal by Court of Appeal for Ontario (judgment)
Outcome
Appeal dismissed; trial judge's declaration of death and orders upheld
Legal Topics
Presumption of Death, Declarations of Death Act S.2(4), Joint Tenancy and Survivorship, Constructive Trust, Adjournment, Costs
Source Language
en
Civil Property Estates Family Law Presumption of Death Declarations of Death Act S.2(4) Joint Tenancy and Survivorship Constructive Trust +2 more

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Parties

Jasminka Pavicevic

Appellant

Jeromy Predrag Pavicevic

Appellant

Betty Iannarelli

Respondent

Procedural Posture

Civil Appeal / Decision on Appeal by Court of Appeal for Ontario (judgment)

  1. 1 Whether presumption of death applies after seven years of unexplained absence
  2. 2 Whether criteria of s.2(4) of the Declarations of Death Act were met to declare death as of January 10, 1997
  3. 3 Whether title held in joint tenancy passed on presumed death notwithstanding later registration of a spousal support order

Ratio Decidendi

The trial judge correctly applied the presumption of death and the statutory test in s.2(4) of the Declarations of Death Act, finding sufficient evidence that the missing person had been unaccounted for for more than seven years and declaring death as of January 10, 1997; because the parties held title as joint tenants, title vested automatically in the surviving joint tenant on that date and was not defeated by the later registration of the spousal support order, and there was no basis for appellate intervention on the adjournment or constructive trust findings.

Court Disposition

Appeal dismissed; trial judge's declaration of death and orders upheld

Orders

  • Appeal dismissed
  • Declaration of death affirmed as at January 10, 1997