G.R. No. 162934 - Heirs of Castillo vs. Lacuata-Gabriel

On January 25, 1989, Crisanta Yanga-Gabriel died in Malabon City, leaving a sizable estate mainly consisting of real estate and shares of stock.
Her mother, Crisanta Santiago Vda. de Yanga, filed an intestate proceeding before the Regional Trial Court (RTC) of Malabon City, alleging the estate was worth approximately ₱1,500,000.00.
She requested letters of administration for her son, Mariano Yanga, Jr., and sought to be awarded her share after hearing.
The RTC initially appointed Lorenzo Almoradie, Crisanta’s husband, as administrator. Later, upon declaration of Lorenzo’s bigamous marriage to Crisanta, Lorenzo was removed and Mariano Yanga, Jr. was appointed administrator.

On October 16, 1989, Belinda Dahlia Y. Almoradie Castillo, claiming to be the only legitimate child of Lorenzo and Crisanta, filed a motion for intervention.
Resolution on her motion was deferred pending related incidents in the Court of Appeals (CA).
On November 3, 1989, Roberto Y. Gabriel, the legally adopted son of Crisanta, filed a petition for probate of an alleged will naming him sole heir and alternate executor.

The intestate and probate proceedings were consolidated; on May 15, 1991, the RTC dismissed the intestate proceedings.
Mariano Yanga, Jr. questioned the dismissal via petition for certiorari, which was later dismissed by the CA.
On May 23, 2001, the heirs of Belinda (Bena Jean, Daniel, Melchor, Michael, Danibel Castillo) sought substitution as party-litigants due to Belinda’s death in 1990.
After Roberto Gabriel died on April 16, 2001, his widow, Dolores L. Gabriel, sought to be admitted as his substitute and to be appointed administratrix of Crisanta’s estate.
Dolores claimed to have a law degree and legal work experience; the heirs of Belinda opposed her claim, denying her kinship and spouse status.
Dolores refuted these allegations and, on August 24, 2001, Bena Jean Castillo moved to be appointed administratrix of Crisanta’s estate, which Dolores opposed.

On December 5, 2001, the probate court appointed Dolores as special administratrix after finding she sufficiently proved kinship to Roberto Gabriel and, by law, relationship to Crisanta.
The probate court held that appointment of special administrators is temporary and governed by different rules than regular administrators.
Dolores took her oath on January 11, 2002; the probate court denied the heirs’ motion for reconsideration on March 19, 2002.
The heirs filed a petition for certiorari before the CA seeking to nullify the orders and requesting appointment of Bena Jean as regular administratrix.
On October 30, 2003, the CA dismissed the petition, ruling no grave abuse of discretion was committed in appointing Dolores special administratrix.

The heirs of Belinda Castillo filed a petition for review on certiorari before the Supreme Court.
They argued:

The CA misapprehended facts.
Dolores is not entitled as she is not an heir of Crisanta but only heir of her deceased husband whose estate derived from Crisanta.
Appointment of Dolores violates prior Supreme Court rulings (e.g., Gonzalez v. Guido).
The wrong procedural rule was applied—Section 6, Rule 78 (regular administration) applicable, not Section 1, Rule 80 (special administration).

Whether the appointment of respondent Dolores Lacuata-Gabriel as special administratrix of the estate of Crisanta Yanga-Gabriel was proper.
Whether the order of preference in the appointment of regular administrators per Section 6, Rule 78 of the Rules of Court applies to the appointment of a special administrator under Section 1, Rule 80.
Whether the heirs of Belinda Dahlia Castillo have standing and superior right to administer Crisanta’s estate compared to Dolores.