G.R. No. L-42678 - Baybayan vs. Aquino

In January 1960, a petition for the summary settlement of the estate of Vicente Oria, who died intestate in 1945 in Balungao, Pangasinan, was filed by private respondents (Norberto, Paulina, Felisa Padua; Dionisia, Laureano, Leonardo, Josefina, Valentina Orpiano; Servillano, Gertrudes, Pastora, Lorenzo, Fausta Delfin; and Dionisio, Faustina, Amado, Benjamin Oria).
The petition, filed in the then Court of First Instance of Pangasinan, Tayug Branch (docketed as Special Proceeding No. T-300), sought a summary settlement of an estate valued at no more than P6,000.00.
After due notice, hearing, and the necessary publication, the probate court adjudicated the estate in favor of the heirs and ordered them to submit a project of partition.

In 1971, the case was transferred to the Rosales Branch of the Court of First Instance of Pangasinan (docketed as Spec. Proc. No. 24-R).
On 18 September 1974, the probate court confirmed its earlier adjudication and ordered Eulalia Evangelista to account for and distribute the produce of the estate among the heirs.
Subsequent to confirmation, a writ of execution and later a writ of possession were issued, putting the private respondents in possession of their respective shares of the estate.

A dispute arose when a representative of the private respondents, during an attempt to cultivate the adjudicated land, was prevented from doing so by Jose Diaz and Cipriano Evangelista.
The private respondents subsequently filed a motion in Spec. Proc. No. 24-R to hold Diaz and Evangelista in contempt of court.

Petitioners Pedro Baybayan, Cipriano Evangelista, and spouses Bartolome and Consuelo Baybayan, claiming registered ownership of the lots through Transfer Certificates of Title Nos. 50269 and 50270, filed a complaint in Civil Case No. 231-R in the Court of First Instance of Pangasinan, Rosales Branch.
Their complaint sought quieting of title, recovery of ownership or possession of the property, and damages, as well as an injunction to restrain enforcement of the writ of execution issued in Spec. Proc. No. 24-R.

During the contempt proceedings, questions arose regarding the identity of the lands subject to Spec. Proc. No. 24-R.
The probate court ordered a relocation survey, and the commissioned geodetic engineer’s report indicated that the lands delivered under the writ of possession were registered in the petitioners’ names.
In an order dated 30 October 1975, the probate court dismissed the contempt charge against Jose Diaz and Cipriano Evangelista and directed the petitioners to file an amended complaint in Civil Case No. 231-R excluding Lot E.
The petitioners subsequently filed an Omnibus Motion with an amended complaint; however, the respondent Judge found that the amendments did not comply with his order and dismissed the case “without prejudice” on the ground that a proper complaint must be filed to recover Lot B (formerly covered by OCT No. 23684, now under TCT No. 50269).
A motion for reconsideration of the dismissal was filed by the petitioners but was denied on 24 December 1975.
Thereafter, the petitioners elevated the issue to the Supreme Court via a petition for certiorari.

The petitioners, by filing in Civil Case No. 231-R and later submitting an Omnibus Motion, voluntarily submitted themselves to the probate court’s jurisdiction despite the proceedings originating from Spec. Proc. No. 24-R, where they were not originally parties.
Their counsel argued that the respondent Judge lacked jurisdiction under both substantive and procedural law, especially since the order to amend the complaint was issued in connection with a special proceeding in which they were not involved.

Whether the respondent Judge had the authority to issue an order directing the petitioners to amend their complaint despite the proceedings originating in Spec. Proc. No. 24-R, where the petitioners were not parties.
Whether the dismissal of the complaint for failing to comply with the order to amend the complaint (specifically excluding Lot E) amounted to a grave abuse of discretion, effectively lacking jurisdiction.
Whether the determination of the ownership of Lot E by the probate court, after a relocation survey and the geodetic engineer’s report, was final and should bind the petitioners.
Whether the petitioners, having voluntarily submitted themselves to the probate court’s jurisdiction by filing an Omnibus Motion, can now contest the validity of that jurisdiction.