Case Digest (G.R. No. L-69765-67)
Facts:
In Heirs of Sotero A. Punongbayan, represented by Clarita M. Punongbayan [deceased], substituted by her heirs Leticia M. Mapoy, Luisito A. Mendoza, Yolanda M. Dimagiba, Elvira M. Burayag, and Henie N. Punongbayan (collectively, the Heirs of Sotero), co-administrators of the intestate estate of Escolastica Punongbayan Paguio, filed Special Proceeding No. 1053 before the Regional Trial Court (RTC) of Cagayan de Oro City, Branch 19. On May 23, 2001, Sotero filed a Manifestation/Motion seeking the attachment and levy of ₱40 million deposited in Security Bank in the name of St. Peter’s College, Inc., alleging that these funds represented unpaid rent for use of Estate property following the decedent’s death. St. Peter’s College’s interim president, Carmelita Punongbayan, opposed on grounds of non-service and lack of a lease contract. The RTC froze the Security Bank account upon finding prima facie evidence of Estate ownership. St. Peter’s College then filed a complaint in interventionCase Digest (G.R. No. L-69765-67)
Facts:
- Parties and Context
- The Estate of Escolastica Punongbayan Paguio (“the Estate”) is under intestate proceedings (SP No. 1053, RTC-Branch 19, Cagayan de Oro).
- Co-administrator Sotero A. Punongbayan filed a motion to attach P40 million deposited in Security Bank under the name of St. Peter’s College, Inc. (“SPC”) as unpaid rentals for Estate property.
- Intestate Court Actions
- May 23, 2001 RTC Order – froze the Security Bank account (P40 million) upon prima facie finding that the funds belonged to the Estate.
- September 27, 2001 RTC Resolution – denied SPC’s complaint in intervention for lack of basis.
- February 4, 2004 RTC Order – directed transfer of P68 million (less P2 million) to trust accounts in BPI and Land Bank under the joint names of the Estate and SPC, prohibiting withdrawal until ownership is finally determined.
- July 3, 2013 RTC Omnibus Order – held prior orders final, ruled SPC had no personality to assail them, and affirmed that P66 million belonged to the Estate.
- Appellate Proceedings
- SPC filed a Petition for Certiorari before the Court of Appeals alleging the RTC acted in excess of jurisdiction and denied due process.
- August 31, 2017 CA Decision – granted certiorari, nullified the RTC orders for excess of jurisdiction and deprivation of due process, and ordered return of P66 million plus interest to SPC.
- April 2, 2018 CA Resolution – denied the Heirs’ motion for reconsideration.
- The Heirs filed a Petition for Review on Certiorari with the Supreme Court.
Issues:
- Was SPC’s petition for certiorari before the CA fatally defective in form and substance?
- Does SPC have legal personality to file a certiorari petition after denial of intervention in intestate proceedings?
- Did the RTC, acting as an intestate court, have jurisdiction to issue the May 23 2001, February 4 2004, and July 3 2013 orders?
- Is SPC estopped by laches from challenging the RTC orders after prolonged inaction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)