Case Digest (G.R. No. 164108)
Facts:
The case Alfredo Hilado, Lopez Sugar Corporation, First Farmers Holding Corporation v. The Honorable Court of Appeals, The Honorable Amor A. Reyes, Presiding Judge, Regional Trial Court of Manila, Branch 21 and Administratrix Julita Campos Benedicto, G.R. No. 164108, May 08, 2009, Supreme Court Second Division, Tinga, J., writing for the Court.The petitioners are Alfredo Hilado, Lopez Sugar Corporation, and First Farmers Holding Corporation; the respondent administratrix is Julita Campos Benedicto (administratrix Benedicto), and the respondent judge is Amor A. Reyes, presiding judge of RTC Manila, Branch 21. The dispute arises from the intestate settlement of the estate of sugar magnate Roberto S. Benedicto, who died intestate on May 15, 2000, leaving administratrix Benedicto as his widow and an only daughter as heir.
At the time of decedent’s death two civil suits by petitioners against Benedicto were pending in the Regional Trial Court of Bacolod City, Branch 44: Civil Case No. 95-9137 (with petitioner Alfredo Hilado as plaintiff) and Civil Case No. 11178 (with petitioners Lopez Sugar Corp. and First Farmers Holding Corp. as plaintiffs). On May 25, 2000, administratrix Benedicto filed a petition for letters of administration in the Manila RTC under Section 6, Rule 78; the Manila RTC issued letters of administration on August 2, 2000. In January 2001 the administratrix submitted an inventory and a list of liabilities that included the two Bacolod cases, estimating liabilities at P136,045,772.50 and P35,198,697.40 respectively. The Manila RTC later required a complete and updated inventory and appraisal.
On September 24, 2001, petitioners filed a Manifestation/Motion Ex Abundanti Cautela in the Manila intestate proceedings seeking copies of all processes and orders and other participatory reliefs; administratrix Benedicto opposed, denying petitioners’ personality to intervene. Petitioners pursued further motions in the Manila RTC complaining of alleged lapses in the administratrix’s administration and sought deadlines for inventory and accounting. The Manila RTC, by order dated January 2, 2002, denied petitioners’ manifestation/motion on the ground they were not interested parties entitled to intervene in intestate proceedings; their motion for reconsideration was also denied.
Petitioners elevated the matter to the Court of Appeals by petition for certiorari, arguing they had a right to intervene because they were creditors of the decedent in the pending civil actions. On February 27, 2004, the Court of Appeals dismissed the petition, holding that allowance of intervention is within the trial court’s sound discret...(Pro-only)
Issues:
- Do petitioners have the right to intervene in the intestate proceedings of Roberto Benedicto under the Rules of Civil Procedure (Rule 19) or the Rules on Settlement of Estates of Deceased Persons (Rules 73–91)?
- Are petitioners, as contingent creditors whose claims arise from pending tort actions, entitled to be furnished with copies of all processes and orders or pleadings in the intestate proceedings?
- Are petitioners entitled to court-ordered deadlines (and ancillary reliefs) compelling the administratrix to submit a verified and complete inventory and appraisal with BIR assistance, and to render her annual ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)