Facts:

On October 18, 1954, the respondents, Amado V. Samson, Jesus V. Samson, Purificacion Samson Morales, Dolores Samson-Acayan, and Paz Samson-Yorobe, filed an application in the Court of First Instance of Albay to secure letters of administration for the estate of the deceased Jose V. Samson. In this context, Jesus V. Samson was subsequently appointed as a special administrator for the estate. This application faced opposition from the petitioners, who included Josefina N. Samson, the widow of Jose V. Samson, alongside their three minor children, Glenda N. Samson, Manuel N. Samson, and Felix N. Samson. The petitioners sought to have Josefina appointed instead of Jesus as the estate's regular administrator.

Following hearings that extended for nearly two years, Judge Mateo L. Alcasid issued an order on March 12, 1956, appointing Antonio Conda, the Municipal Treasurer of Libon, Albay, as the regular administrator. The special administrator, Jesus V. Samson, was subsequently orde

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Facts:

Background and Parties

• The case involves the administration of the estate of the late Jose V. Samson.
• Petitioners: Josefina N. Samson (the widow) and her three minor children (Glenda Samson, Manuel Samson, and Felix Samson).
• Respondents: Amado V. Samson, Jesus V. Samson, Purificacion Samson Morales, Dolores Samson-Acayan, and Paz Samson-Yorobe.

Initiation of Special Administration

• On October 18, 1954, respondents filed an application in the Court of First Instance of Albay seeking the issuance of letters of administration in favor of Jesus V. Samson for the estate.
• On the same day, Jesus V. Samson was appointed as the special administrator.
• The application by Jesus V. Samson and the appointment occurred amidst conflicting interests among family members regarding who should handle the estate.

Petitioners’ Opposition and Subsequent Proceedings

• Petitioners opposed the special administration favoring Jesus V. Samson and requested letters of administration in favor of Josefina N. Samson, the widow.
• After nearly two years of hearings, Judge Mateo L. Alcasid issued an order on March 12, 1956, appointing Antonio Conda, the Municipal Treasurer of Libon, Albay, as the regular administrator.
• The order simultaneously instructed the special administrator to turn over all properties and funds of the estate to the regular administrator within twenty (20) days after receipt of the order.
• Antonio Conda posted the required bond, and on March 19, 1956, letters of administration were issued in his favor.

Subsequent Court Orders and Appeals

• On April 3, 1956, following a motion filed by the widow, the court ordered Jesus V. Samson to deliver all properties and funds in his possession to the regular administrator within three (3) days.
• On March 27, 1956, respondents appealed the issuance of letters of administration in favor of Antonio Conda, with the record on appeal being approved on April 17, 1956.
• On April 20, 1956, respondents filed a motion to set aside the approval of Conda’s bond and his appointment as the regular administrator, which was denied by an order on May 9, 1956.

Intervention of the Appellate Courts and the Supreme Court

• The Court of Appeals, upon certiorari applied for by the special administrator and his supporters, set aside Antonio Conda’s appointment and annulled his bond.
• The appellate decision was based on prior jurisprudence, particularly relying on the principle that the appointment and removal of a special administrator are interlocutory matters under the discretion of the court.
• The applicants for review sought certiorari before the Supreme Court, which granted the petition for review, prompting the higher court’s analysis of the proper exercise of judicial discretion in these proceedings.

Legal Framework and Discretionary Considerations

• The Supreme Court noted that the appointment and removal of a special administrator are incidental proceedings relying on judicial discretion, as seen in prior decisions (e.g., Roxas vs. Pecson, Junquera vs. Borromeo, De Gala vs. Gonzales).
• Rule 81, Section 3 of the Rules of Court mandates that once letters of administration are granted, the power of the special administrator ceases, and the estate must be delivered to the executor or administrator.
• The order of April 3, 1956, although issued pending appeal, was considered effective due to good reasons found in the record, notwithstanding the lack of explicit articulation in that specific order.

Issue:

• Whether the removal (or supersession) of the special administrator by the appointment of a regular administrator was proper and within the sound discretion of the court.
• Whether the court’s action in expediting the administration of the estate, including the immediate execution of the order requiring the turnover of estate properties, was justified under the Rules of Court despite pending appeals.
• Whether the appointment of Antonio Conda as regular administrator, in light of the prolonged special administration and the potential for familial conflicts, was in the interest of justice and the prompt settlement of the estate.
• Whether the appeals and motions filed by respondents to set aside Conda’s appointment and bond were procedurally and substantively valid given the statutory framework governing special and regular administrators.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)