Case Digest (G.R. No. 38036)
Facts:
The case involves a petition for a writ of certiorari filed by Martiniano Benigno against Bernardo de la Peña, the Judge of the Court of First Instance of Ilocos Norte, and Gaspar Acacio, the appointed administrator of the estate. The events leading to this petition began on February 21, 1924, when Gaspar Acacio applied to the Court of First Instance of Ilocos Norte for the summary settlement of the estate of spouses Lorenzo Acacio and Norberta Benigno, who had died intestate in the municipality of Vintar, Ilocos Norte, in 1921 and 1923, respectively. Acacio claimed that the deceased left no ascendants or descendants and that their combined property did not exceed P3,000 in value, with no outstanding debts. The heirs were identified as the siblings of Lorenzo Acacio and Norberta Benigno. The court scheduled a hearing for December 11, 1924, and ordered personal notice to interested parties, along with publication of the order.
On the same date, Martiniano Benigno, who is the...
Case Digest (G.R. No. 38036)
Facts:
Background of the Case:
- On February 21, 1924, Gaspar Acacio filed a petition in the Court of First Instance of Ilocos Norte for the summary settlement of the estate of the deceased spouses Lorenzo Acacio and Norberta Benigno.
- Lorenzo Acacio and Norberta Benigno died intestate in 1921 and 1923, respectively, in Vintar, Ilocos Norte.
- They left no descendants or ascendants, and their heirs were their siblings or their children.
- The estate consisted of conjugal properties valued at approximately P2,000, with no outstanding debts.
Proceedings in the Lower Court:
- The court set the petition for hearing on December 11, 1924, and ordered personal notice to interested parties and publication of the order as required by law.
- Martiniano Benigno, the petitioner, filed an amended opposition on December 11, 1924, claiming that some of the properties in the estate had been sold to him by the deceased spouses.
- Judge C. Carballo issued an order on December 17, 1924, finding that:
- Norberta Benigno died in 1919, and Lorenzo Acacio died in 1923.
- The properties were conjugal, and the heirs were the siblings or their children.
- Martiniano Benigno, son of Clemente Benigno (Norberta’s brother), was in possession of some properties and was the only one opposing the petition.
- The court ordered the estate to be divided equally: one-half to Lorenzo Acacio’s heirs (divided into five parts) and the other half to Norberta Benigno’s heirs (divided into three parts).
- Gaspar Acacio was appointed administrator to recover properties in the possession of third parties, including Martiniano Benigno.
Subsequent Actions:
- On May 18, 1925, Gaspar Acacio, as administrator, filed Civil Case No. 2633 against Martiniano Benigno to recover properties allegedly belonging to the estate.
- Martiniano Benigno attempted to have the December 17, 1924, order set aside on March 25, 1929, and July 16, 1932, but his motions were denied.
- Martiniano Benigno filed the present petition for certiorari, seeking to nullify the December 17, 1924, order, the appointment of Gaspar Acacio as administrator, and to halt further proceedings in the related cases.
Issue:
- Whether the summary settlement of the estates of Lorenzo Acacio and Norberta Benigno in a single proceeding was lawful.
- Whether the appointment of Gaspar Acacio as administrator to recover properties in the possession of third parties was authorized by law.
- Whether Martiniano Benigno, as a non-heir, has the legal standing to challenge the orders and proceedings in the estate settlement.
Ruling:
The Supreme Court denied the petition for certiorari. The Court held that:
- The summary settlement of the estates of Lorenzo Acacio and Norberta Benigno in a single proceeding was proper because the properties involved were conjugal.
- The appointment of Gaspar Acacio as administrator to recover properties in the possession of third parties was lawful and necessary.
- Martiniano Benigno, as a non-heir, had no legal standing to challenge the orders and proceedings in the estate settlement.
Ratio:
- Single Proceeding for Conjugal Property: The Court distinguished the case from Sy Hong Eng vs. Sy Lioc Suy (10 Phil. 209), where separate estates of different persons were involved. Here, the properties were conjugal, and a single proceeding was appropriate for their settlement.
- Appointment of Administrator: The appointment of an administrator to recover properties in the possession of third parties was authorized by law, especially when such properties were part of the estate.
- Lack of Standing: Martiniano Benigno, not being an heir of the deceased spouses, had no legal right to challenge the orders or the appointment of the administrator. His claims of ownership over some properties were matters to be resolved in the pending civil case (No. 2633).
- Timeliness of Petition: The petition was filed more than seven years after the issuance of the December 17, 1924, order, and the related civil case had already been tried and was pending decision. The Court found no reason to set aside the order or halt the proceedings.