Case Digest (G.R. No. 146875)
Facts:
In Hilado v. Court of Appeals, G.R. No. 164108, decided May 8, 2009 under the 1987 Constitution, sugar magnate Roberto S. Benedicto died intestate on May 15, 2000, survived by his wife Julita Campos Benedicto (Administratrix Benedicto) and daughter Francisca Benedicto-Paulino. At his death, two civil suits for damages filed by petitioners Alfredo Hilado (Civil Case No. 95-9137) and Lopez Sugar Corporation with First Farmers Holding Corporation (Civil Case No. 11178) were pending before the Regional Trial Court (RTC) of Bacolod City, Branch 44. On May 25, 2000, Julita Benedicto petitioned the RTC of Manila, Branch 21, for letters of administration, acknowledging estate assets at ₱5 million net of liabilities. The RTC granted her appointment on August 2, 2000. In January 2001, she filed an inventory and listed as liabilities the two pending civil cases, valuing them at ₱136,045,772.50 and ₱35,198,697.40 respectively. Petitioners then sought copies of all intestate‐court processesCase Digest (G.R. No. 146875)
Facts:
- Death of Roberto S. Benedicto and appointment of administratrix
- Roberto S. Benedicto, a sugar magnate, died intestate on 15 May 2000, survived by his wife Julita Campos Benedicto (administratrix) and daughter Francisca Benedicto-Paulino.
- Two civil cases against Benedicto were pending in Bacolod RTC Branch 44: Civil Case No. 95-9137 (Hilado) and Civil Case No. 11178 (Lopez Sugar Corp. & First Farmers Holding Corp.).
- On 25 May 2000, Julita Campos Benedicto filed for letters of administration in Manila RTC Branch 21; she was appointed administratrix on 2 August 2000.
- Inventory, discovery requests, and motions in Manila RTC
- In January 2001, administratrix submitted inventory listing liabilities of ₱136,045,772.50 (Case No. 95-9137) and ₱35,198,697.40 (Case No. 11178).
- Manila RTC required a complete and updated inventory and appraisal report.
- On 24 September 2001, petitioners filed a Manifestation/Motion ex abundanti cautela for copies of all processes and orders; administratrix opposed, disputing petitioners’ personality to intervene.
- Petitioners filed omnibus motion for deadline to submit inventory and later other motions alleging lapses in administration; RTC denied intervention on 2 January 2002.
- Court of Appeals and Supreme Court proceedings
- Petitioners sought reconsideration; RTC denied it.
- Court of Appeals dismissed petition for certiorari on 27 February 2004, holding petitioners lacked actual, material interest to intervene.
- Petitioners advanced Rule on Special Proceedings provisions; Supreme Court granted full briefing and oral arguments, focusing on intervention and special proceeding rights.
Issues:
- Whether petitioners have the right to intervene in the intestate proceedings under Rule 19, Rules of Civil Procedure.
- Whether petitioners, as contingent creditors, have other participatory rights under the Rules on Special Proceedings (Rules 73–91).
- Whether petitioners may obtain specific reliefs:
- Service of all processes and pleadings in the intestate proceedings.
- Court-imposed deadlines for administratrix to file complete inventory and to secure BIR appraisers.
- Court-imposed deadlines for administratrix’s annual account and examination under oath.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)