Facts:

The case at hand involves Herodotus P. Acebedo and Demosthenes P. Acebedo as petitioners against Hon. Bernardo P. Abesamis and several other respondents, including other heirs and Yu Hwa Ping. This case emerged from a probate proceeding concerning the estate of Felix Acebedo, who left properties estimated at around P30 million located in Quezon City and Caloocan City. The estate had several unsettled claims, such as unpaid real estate taxes and outstanding compensation for prior and current administrators, totaling P108,181.00, along with potential inheritance taxes. The decedent was succeeded by eight heirs, with the petitioners being two among them.

Due to the prolonged proceedings over sixteen years in the lower court, the respondents filed a "Motion for Approval of Sale" on October 4, 1989, concerning specific property titles and proposed a sale for P12 million to a buyer, Yu Hwa Ping. They argued that the sale would settle existing claims against the estate and pr

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Facts:

Background of the Estate

• The decedent, Felix Acebedo, left an estate composed of several real property assets in Quezon City and Caloocan City, with an estimated conservative value of about P30 million.
• The estate had unsettled obligations including:
• P87,937.00 in unpaid real estate taxes for Quezon City;
• P20,244.00 in unpaid real estate taxes for Caloocan City;
• Unpaid salaries/allowances of the former administrator, Miguel Acebedo, and the incumbent administrator, Herodotus Acebedo;
• Possible inheritance taxes on the net estate.
• The decedent was succeeded by eight heirs – with two (Herodotus P. Acebedo and Demosthenes P. Acebedo) acting as petitioners and the remaining heirs being private respondents.

Initiation of Judicial and Extrajudicial Proceedings

• Respondents-heirs filed a Motion for Approval of Sale on October 4, 1989, seeking approval to sell properties covered by Transfer Certificate of Title Nos. 155569, 120145, 9145, and 18709.
• The sale was conditional, with a purchase price of P12 million, where an earnest money deposit of P6 million had already been received from buyer Yu Hwa Ping.
• It was claimed that the balance of funds from the sale was sufficient to settle the estate’s claims.
• Petitioner-administrator Herodotus Acebedo filed an Opposition to the approval, raising several concerns:
• Allegations that some heirs had already sold part of the estate (a property at Balintawak, Quezon City) without proper notice, at an unreasonably low price.
• Assertion that the manner of the conditional sale might expose the proponents to potential contempt charges.
• A plea for the Court to authorize either the sale for generating funds for estate liabilities or advance payments to heirs, subject to judicial approval.
• Subsequent motions and pleadings included:
• Petitioners’ motion requesting a forty-five (45) days period to secure a buyer offering a price exceeding P12,000,000.00 (October 30, 1989) and later an additional thirty-day period (February 8, 1990).
• A criminal complaint by petitioner-administrator against Yu Hwa Ping and notary Eugenio Obon for alleged falsification of a public document, following the notarization of the disputed Deed of Conditional Sale.
• Filing of a civil action (April 2, 1990) by petitioner-administrator to obtain a declaration on the nullity of the Deed of Conditional Sale and the Deed of Absolute Sale.
• A supplementary Opposition to Approval of Sale filed by petitioners when Demosthenes Acebedo sought to nullify previous court-approved time extensions for obtaining a better buyer.
• A Motion for Leave of Court to Mortgage and Lease some of the estate properties (June 21, 1990) which faced opposition on several grounds, including the existing pending motion for sale approval and assertions regarding the estate’s financial sufficiency.

Development and Court Conferences

• The lower court, on August 17, 1990, issued an Order denying the sale motion and granting the administrator leave to mortgage some properties, subject to further court approval.
• Subsequent conferences held on December 17, 1990, and January 4, 1991, resulted in an agreement whereby:
• The heirs would be allowed to sell their shares to Yu Hwa Ping at the agreed price.
• Petitioners would attempt to negotiate for a higher price separately.
• A Supplemental Opposition to the approval of the conditional sale was subsequently filed by the petitioners.
• On March 29, 1991, the respondent Court issued an Order that:
• Approved the conditional sale based on the documents executed on September 10, 1989, by the heirs in favor of Yu Hwa Ping.
• Directed petitioner-administrator to sell the remaining portions of the properties under similar terms.
• Ordered that Yu Hwa Ping deposit the remaining balance of the purchase price within twenty (20) days.
• Denied a motion to cite former administrator Miguel Acebedo in contempt.

Post-Approval Motions and Final Developments

• Yu Hwa Ping complied by depositing P6,500,000.00 on April 4, 1991, and petitioners received the challenged Order on April 11, 1991.
• Petitioners filed motions for reconsideration and partial reconsideration subsequently, all of which were denied.
• Private respondents eventually filed a Motion for Execution of the Order on November 7, 1991, leading to the pending controversy ultimately resulting in a Petition for Certiorari by the petitioners challenging the jurisdiction of the lower court.

Issue:

Jurisdictional Question

• Whether the lower court (acting in its capacity as a probate court) had jurisdiction to approve the Deed of Conditional Sale executed by the heirs without obtaining prior approval in a probate proceeding.
• Whether the issuance of the Order, which also directed the administrator to dispose of the remaining portions of the estate properties based on the approved conditional sale, was within the bounds of the court’s authority.

Procedural and Substantive Matters

• The propriety of approving the sale of estate properties under conditions (e.g., the requirement for a buyer’s deposit) stipulated by the court.
• The impact of the conditional nature of the sale on the rights of the heirs, particularly regarding their discretion to market and obtain a higher price for their shares.
• The relevance and application of Section 7, Rule 89 of the Rules of Court in the administration and disposition of a decedent’s estate.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)