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...

Facts:

Background of the Estate Settlement

• On February 21, 1924, Gaspar Acacio, acting as petitioner in the summary settlement proceedings, applied to the Court of First Instance of Ilocos Norte for the summary settlement of the estate of two deceased spouses, Lorenzo Acacio and Norberta Benigno.
• It was alleged that:
• The spouses died intestate in the municipality of Vintar, Ilocos Norte (Norberta in 1921 or as later determined in 1919, and Lorenzo in 1923).
• They had no ascendants or descendants.
• The properties acquired during their marriage—which did not exceed P3,000 in value—constituted their conjugal estate.
• There were no outstanding debts at the time of their deaths.
• The heirs of Lorenzo Acacio were his brothers, sisters, or their children; while the heirs of Norberta Benigno were her brothers or their children.

Proceedings and Findings by the Court

• The petition was set for hearing on December 11, 1924, with personal and published notices given to interested parties.
• On December 11, 1924, Martiniano Benigno, claiming that some of the properties described in the petition had been sold to him by the deceased spouses, filed an amended opposition.
• Judge C. Carballo, in hearing the matter on December 17, 1924, dictated an order with the following findings:
• Norberta Benigno died in 1919 and Lorenzo Acacio in September 1923.
• The spouses were husband and wife who died intestate and left no descendants or ascendants.
• The nearest relatives, identified in the petition, were recognized as the heirs.
• The estate comprised real properties valued at approximately P2,000.
• All properties were identified as conjugal properties, with some being in the possession of Martiniano Benigno, the son of one of Norberta’s brothers.
• The court ordered:
• The estate be divided into two equal parts: one-half among the heirs of Lorenzo Acacio (five equal parts) and the other among the heirs of Norberta Benigno (three equal parts).
• Gaspar Acacio be appointed as administrator, subject to his filing a bond of P500, with authority to file an action for recovery of properties held by third persons.
• Subsequent proceedings included:
• Notification of Martiniano Benigno on December 17, 1924 regarding the order.
• On May 18, 1925, Gaspar Acacio, as administrator, filed civil action No. 2633 to recover certain properties.
• The petitioner, Martiniano Benigno, attempted through motions on March 25, 1929, and July 16, 1932 to have the order set aside; however, these motions for reconsideration were overruled.

Petition for Writ of Certiorari

• Martiniano Benigno’s current petition seeks:
• To enjoin further proceedings in both the summary settlement case and the civil action for recovery (civil case No. 2633).
• For the December 17, 1924 order, including the appointment of Gaspar Acacio as administrator, to be declared null and void.
• The petitioner’s principal arguments include:
• The alleged impermissibility of settling the estates of two persons (the deceased spouses) in a single proceeding.
• The contention that the appointment of an administrator for recovery actions against third-party possessors was unauthorized.

Additional Relevant Details

• The matter pertained solely to the conjugal property of the deceased, suggesting a unified estate despite the existence of two decedents.
• The case records indicate that there was a complete trial in the civil action concerning the recovery of certain properties, a decision on which was pending.
• The petitioner’s allegations were countered by the court’s findings that all required legal procedures were properly fulfilled.

Issue:

• Whether the settlement of the estates of two deceased persons (the spouses) in a single proceeding is legally proper when dealing with a unified conjugal estate.
• Whether the appointment of Gaspar Acacio as administrator, including his authority to initiate an action to recover properties held by third persons, was authorized by law.
• Whether the petitioner, Martiniano Benigno—who is not clearly established as an heir—has the legal standing to contest the order and the appointment of the administrator.
• Whether the reliance on prior case law (specifically Sy Hong Eng vs. Sy Lioc Suy) is applicable and determinative of the present proceedings.

Ruling:

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Ratio:

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Doctrine:

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