G.R. No. L-51368 - People vs. Macatanda

Gregorio Navarro died, leaving behind a widow, several minor children, and both real and personal property.
On December 9, 1910, the Court of First Instance of Ilocos Sur appointed:

Prospero K. Alafriz duly qualified as administrator on March 10, 1911.
The administrator filed a motion in the Court of First Instance alleging that Pia Mina was in possession of a document or receipt (a pawn ticket) relating to jewelry deposited by the deceased as security for a loan obtained from Salvador Rivero and his wife.
The motion sought:

Pia Mina to be cited to appear in court.
Verification on whether she indeed possessed the paper or document evidencing the deposit.

On March 13, 1911, Judge Dionisio Chanco issued an order citing Pia Mina to appear on March 22, 1911, at 8 a.m. to respond to the allegations.
On March 22, 1911, Pia Mina appeared in court, and the judge ordered her:

On March 23, 1911, Pia Mina complied by depositing pawn ticket No. 243 with the clerk, but she also:

The court ordered the administrator to deposit ₱160 (the loan amount) with the clerk.
The clerk was instructed to redeem the jewelry and to keep it in custody until the final settlement of the estate.

The clerk redeemed the jewelry on the same day.
On April 8, 1911, Pia Mina filed a motion to exclude the jewelry (represented by pawn ticket No. 243) from the inventory submitted by the administrator.

The matter was heard on April 28, 1911.
During the hearing, Pia Mina offered to present proof of her and her mother’s ownership.
The administrator objected, and the court sustained his objection; Pia Mina duly excepted.

The court denied the petition to remove Prospero K. Alafriz as administrator.
It enjoined strict adherence to its earlier orders dated December 9, 1910, and March 28, 1911.
The order provided that:

The administrator and Pia Mina could institute separate actions to determine their respective rights regarding the jewelry.
The pawned jewelry was to remain with the clerk until a competent court finally decided on the question of possession and ownership.
Pia Mina was directed to furnish a bond for the proper discharge of her duties as guardian of her minor children.
The administrator was instructed to submit a detailed inventory in compliance with legal requirements and to take all necessary steps for a proper settlement of the intestate estate.

The improper summoning of a person (herself) in a testamentary proceeding.
The order directing her to present the pawn ticket.
The order authorizing the clerk to redeem and retain the jewelry using estate funds.
The refusal to allow the introduction of evidence on the ownership of the jewelry.
The inclusion of the jewelry in the administrator’s inventory without positive proof of its belonging to the estate.
The failure to remove the administrator from office and to appoint her in his stead.

The summoning of a suspected person (Pia Mina) to appear and be examined on oath regarding documents or evidence related to the estate.
The procurement and submission of the pawn ticket under court order.

Ordering the clerk to redeem the pawned jewelry with the funds of the estate.
Taking possession of the pawn ticket and jewelry without affording Pia Mina an opportunity for a hearing on her claim of ownership.

Whether the exclusion of evidence pertaining to the ownership of the jewels, and the inclusion of such disputed property in the inventory of the estate, deprived Pia Mina of her rights.
Whether the failure to remove Prospero K. Alafriz as administrator, and to appoint Pia Mina instead, was erroneous given the circumstances of the case.