Facts:

• The case involves Teresita N. de Leon, Zenaida C. Nicolas, and the heirs of Antonio Nicolas as petitioners.
• Respondents include the Hon. Court of Appeals, Hon. Pablo P. Inventor, and Ramon Nicolas.
• Teresita was appointed administratrix of Rafael C. Nicolas's estate in Special Proceedings No. C-1679.
• This case was consolidated with Special Proceedings No. C-1810 and Civil Case No. C-17407.
• Rafael and Salud Nicolas were the deceased parents of Teresita and her siblings, including Ramon and Antonio.
• On September 19, 1994, Ramon G. Nicolas filed a Motion for Collation, claiming certain properties were given to Rafael's children during his lifetime and were omitted from the estate inventory.
• The properties in question were located in Polo, Bulacan, and Caloocan City.
• The Regional Trial Court (RTC) ordered Ramon to submit documents regarding property transfers on September 27, 1994.
• An Amended Motion for Collation was filed by Ramon on October 10, 1994, detailing the properties to be collated.
• On November 11, 1994, the RTC ordered the inclusion of certain properties in the estate inventory.
• Teresita's Motion for Reconsideration was denied, leading to further motions regarding her removal as administratrix and property collation.
• The Court of Appeals ruled that the RTC's order became final due to the petitioners' failure to appeal timely, prompting a review on certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the Order dated November 11, 1994 was interlocutory in nature and not final.
• The Court of Appeals erred in determining that the...(Unlock)

Ratio:

• The Supreme Court held that the RTC's Order dated November 11, 1994, directing the inclusion of certain properties in the estate inventory, was interlocutory and not final.
• The ruling was based on the principle that a probate court can supervise and control a deceased person's properties, but its decisions on property inclusion or exclusion are provisional.
• The ...continue reading