Facts:

The case arises from the estate of Sotero Baluyut, who passed away on January 6, 1975, in Manila at the age of eighty-six, leaving behind an estate allegedly valued at over two million pesos. On February 20, 1975, Alfredo G. Baluyut, the deceased’s nephew, filed a verified petition for letters of administration in the Court of First Instance of Quezon City. In his petition, he claimed that the deceased was survived by his widow, Encarnacion Lopez, who he alleged was mentally incapable of serving as administratrix of the estate. Believing that Sotero Baluyut had executed a will, Alfredo requested to be appointed as both a special and regular administrator. The court initially appointed him as a special administrator with a bond amount of P100,000 on February 24, 1975.

However, Encarnacion Lopez opposed this appointment on March 8, 1975, asserting her ignorance of any will and contesting the claims regarding her mental incapacity, even labeling them as libelous. Consequently, the

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Facts:

Overview of the Decedent and Estate

• Sotero Baluyut, aged 86, died on January 6, 1975, in Manila.
• His estate was allegedly valued at not less than two million pesos.
• There was an allegation that he had executed a notarial will on April 14, 1973, which later became relevant to the proceedings.

Initiation of Probate Proceedings

• On February 20, 1975, Alfredo G. Baluyut, the deceased’s nephew, filed a verified petition for letters of administration in the Court of First Instance of Quezon City.
• Alfredo alleged that the decedent’s widow, Encarnacion Lopez Vda. de Baluyut, was mentally incapable of serving as administratrix.
• He also surmised that the decedent had executed a will, which influenced his petition to be both the regular administrator and, during the interim, the special administrator.

Orders and Movements by the Lower Court

• The lower court initially issued an order on February 24, 1975, appointing Alfredo as special administrator with a bond of P100,000.
• Mrs. Baluyut filed a verified opposition on March 8, 1975, denying any knowledge of a will and vehemently refuting the allegation of mental incapacity as libelous.
• On March 24, 1975, the court cancelled Alfredo’s appointment as special administrator after finding, through her testimony during examination, that Mrs. Baluyut was “healthy and mentally qualified.”
• On March 31, 1975, after Alfredo’s motion for reconsideration, the court reappointed both Alfredo G. Baluyut and Jose Espino as special administrators.
• In an amended verified opposition filed on September 2, 1975, Mrs. Baluyut suggested that if she were not appointed administratrix, then Espino (alleged to be a natural child of Sotero Baluyut and former governor of Nueva Vizcaya) should be so named.

Further Developments and Urgent Motions

• Mrs. Baluyut filed an urgent motion on November 12, 1975, praying to be appointed administratrix.
• The motion was based on her claim that Alfredo had lost any interest in the estate—as a collateral relative—and that the appointment should reflect her surviving spouse’s preferential rights (entitling her to three-fourths of the conjugal estate).
• Alfredo opposed the motion by alleging:
• That Espino was not a natural child of Sotero Baluyut, citing the legitimate parentage of Espino as the spouses Elino Espino and Josefa de Guzman.
• That Mrs. Baluyut had been declared incompetent by the Juvenile and Domestic Relations Court of Quezon City in a guardianship proceeding initiated by her sisters.

Witness Examination and Court’s Subsequent Action

• At the hearing on November 17, 1975, the court interrogated Mrs. Baluyut briefly:
• Questions were asked regarding her language proficiency, dates, and personal background.
• When questioned about her relationship with Gov. Espino, she affirmed that he was “like a son” and later, when directly asked, stated that he was her son.
• No further oral or documentary evidence by Alfredo was taken during this hearing.
• On November 27, 1975, the probate court issued an order:
• Terminating the appointments of both Alfredo G. Baluyut and Jose Espino as special administrators.
• Appointing Mrs. Baluyut as regular administratrix with a bond of P20,000, basing the decision on her status as the surviving spouse with a preferential right under the Rules of Court.
• Mrs. Baluyut took her oath of office on November 29, 1975.

Special Civil Action for Certiorari and Subsequent Allegations

• On December 13, 1975, Alfredo filed a special civil action of certiorari against:
• The respondent judge.
• Mrs. Baluyut.
• The Espino spouses.
• A restraining order was issued by the Supreme Court to enjoin the enforcement of the November 27 order and to prevent the respondents from disposing of estate assets.
• In their comments, the respondents raised:
• That Alfredo was aware of a notarial instrument wherein Sotero Baluyut acknowledged Jose Espino as his natural child.
• Claims by Mrs. Baluyut that Alfredo’s administration proceeding was motivated by personal gain—citing an alleged fraudulent demand for a check and misrepresentations regarding her competence.
• Alfredo, in his February 2, 1976 manifestation, disclosed the existence of a notarial will executed by Sotero Baluyut, which bequeathed:
• To Mrs. Baluyut—his one-half share in certain conjugal assets and one-fourth of the residue of his estate, with her also designated as executrix.
• The remaining three-fourths to collateral relatives bearing the surnames Baluyut and Miranda.

Procedural Posture and Additional Motions

• A pending motion by Alfredo (January 15, 1976) seeking to enjoin the respondent judge from acting on Mrs. Baluyut’s motion for appointing Espino as special administrator was ultimately denied after Alfredo manifested it as moot on April 2, 1976.
• The consolidated issues raised questions on the proper course of probate procedure given the competing interests and the alleged grave abuse of discretion by the lower court.

Issue:

Whether the probate court committed grave abuse of discretion by:

• Summarily appointing Mrs. Baluyut as administratrix without affording a full-dress hearing on her competency.
• Failing to allow Alfredo G. Baluyut an opportunity to contest her qualifications, despite his expressed interest and opposition.

• Whether the presumption of Mrs. Baluyut’s mental capacity, based on a brief and perfunctory interrogation, was sufficient in light of the contested issues regarding her competency.

• Whether the procedural transformation of the administration proceeding into a testamentary proceeding (given the existence of a notarial will) was necessary and should have been strictly observed prior to the appointment of an administratrix/executrix.

• Whether the lower court’s assumption that Alfredo had no interest in the estate—which influenced its decision—was correct, especially considering his later disclosure of the will naming him as a legatee.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)