G.R. No. 132988 - Pimentel, Jr. vs. Aguirre

The late Felix Acebedo left an estate comprising several real estate properties in Quezon City and Caloocan City, with an estimated value of about P30 million.
The estate had unsettled claims including unpaid real estate taxes (P87,937.00 in Quezon City and P20,244.00 in Caloocan City), unpaid salaries of former and incumbent administrators, and possible inheritance taxes.
The decedent was survived by eight heirs, including the petitioners Herodotus P. Acebedo and Demosthenes P. Acebedo, and the rest as respondents.

Due to the prolonged pendency of the estate administration case (16 years), respondent-heirs filed on October 4, 1989, a Motion for Approval of Sale of certain estate properties covered by Transfer Certificate of Title (TCT) Nos. 155569, 120145, 9145, and 18709, all in Quezon City.
The proposed sale was for twelve million pesos (P12,000,000.00), with a buyer identified as Yu Hwa Ping who already paid six million pesos as earnest money; the remaining six million pesos was considered sufficient to pay unsettled claims and distribute residue among heirs.
The petitioners-administrators opposed the sale, arguing it was executed without their knowledge or court approval, at a shockingly low price, and prayed for court authorization to look for a buyer offering the highest price, subject to court approval.

Petitioners sought several extensions (starting October 30, 1989) to look for a buyer willing to pay more than twelve million pesos but failed to find one.
Petitioner Herodotus Acebedo filed a criminal complaint for falsification of a public document against buyer Yu Hwa Ping and notary Eugenio Obon after discovering purportedly forged signatures in the Deed of Conditional Sale. The notary revoked his notarization.
A civil action for nullity of the Deed of Conditional Sale and Deed of Absolute Sale was filed by the petitioner-administrator on April 2, 1990.
Respondents and petitioners continued to dispute the approval and validity of sale orders, motions for mortgage leases, and other administrative actions related to the estate properties through late 1990 and early 1991.

On August 17, 1990, the court denied the motion to approve sale but granted leave to mortgage some properties subject to just and reasonable terms and court approval.
Subsequent conferences in December 1990 resulted in partial agreement allowing heirs to sell their shares to the buyer while petitioners continued to negotiate for a better price.
On March 29, 1991, the court reversed its previous denial and approved the conditional sale executed by heirs to Yu Hwa Ping, ordered the administrator to sell the remaining portions at the same price, and required the buyer to deposit the balance within 20 days.
Yu Hwa Ping deposited the remaining balance on April 4, 1991.
Petitioners filed motions for reconsideration and partial reconsideration, all of which were denied by the probate court by October 1991.
Respondents then filed a motion for execution of the March 29, 1991 order pending the present petition for certiorari.

The question arose whether the probate court had jurisdiction to approve the Deed of Conditional Sale executed by respondents-heirs without prior court approval and to order the administrator to sell the residual portions of the properties.

Whether or not the probate court had jurisdiction to approve the Deed of Conditional Sale executed by the respondents-heirs without prior court approval.
Whether the probate court could validly order the administrator to sell the remaining portions of the said estate properties.
Whether the conditional sale without prior court approval constitutes a nullity.
Whether an heir can sell his or her interest in the estate undergoing administration prior to final adjudication.