Facts:

The case, Teresa R. Ignacio v. Ramon Reyes et al., G.R. No. 213192, was decided by the Supreme Court of the Philippines on July 12, 2017. The respondent Ramon Reyes, along with Florencio Reyes Jr., Rosario R. Du, and Carmelita R. Pastor, initiated a petition against Teresa R. Ignacio, the administratrix of the estate of Florencio Reyes Sr., who had passed away on June 23, 1967. Following Florencio Sr.'s death, Angel Reyes and Oliva R. Arevalo filed a petition for Letters of Administration for his estate on July 11, 1967, identifying several heirs, including Teresa. The court appointed Oliva as special administratrix, and later, Florencio Jr. replaced her in 1982. Eventually, Teresa assumed the role of administratrix on August 8, 1994.

During her tenure as administratrix, Teresa executed multiple lease contracts for various properties in Baguio City, including a 398-square meter parcel on Magsaysay Avenue and a 646-square meter parcel on Session Road, which were leased to dif

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Facts:

Estate Administration and Initial Proceedings

• On July 11, 1967, Angel Reyes and Oliva R. Arevalo filed a petition for Letters of Administration of the estate of Florencio Reyes, Sr., who died on June 23, 1967, before the then Court of First Instance of Rizal (now the RTC of Pasig City, Branch 151).
• The petition identified the surviving heirs, including Oliva, Francisca Vda. de Justiniani, Angel, Amparo R. Avecilla, Ramon Reyes, Teresa, Rosario R. Du, Jose Reyes, Soledad Reyes, Carmelita R. Pastor, and Florencio Reyes, Jr.
• Initially, the intestate court appointed Oliva as special, then regular, administratrix, with subsequent replacement by Florencio Reyes, Jr. in 1982 and eventually Teresa becoming the administratrix on August 8, 1994.

Leasing of Estate Properties

• On December 5, 1994, Teresa executed a lease contract for a 398-square-meter parcel of land at Magsaysay Avenue, Baguio City (covered by TCT No. T-59201), in favor of several parties including Gonzalo Ong and Virginia Lim.
• The intestate court, on Teresa’s motion, approved the lease in an Order dated July 15, 1996.
• On September 26, 1996, the court allowed Teresa to lease another property, located at Session Road, Baguio City (646 square meters, TCT No. T-26769), to Famous Realty Corporation, culminating in a lease executed on October 29, 1996, for the period from July 1, 1996, to June 30, 2003, at a monthly rental of P135,000.00.
• Around January 1997, Teresa also leased properties on Loakan Road, Baguio City (TCT Nos. T-26770 and T-26772) to ATC Wonderland, Inc. and later to Gloria de Guzman and Sonshine Pre-School, with the lease period set from September 1, 1996, to August 31, 2006.

Disputes and Claims for Partition

• On September 25, 2001, respondents Ramon, Florencio Jr., Rosario, Carmelita, and other heirs filed three complaints for partition, annulment of lease contracts, accounting, and damages before the RTC of Baguio City, Branch 3.
• The plaintiffs claimed that, apart from the lessees, all parties—including the Florencio Sr. estate and the heirs—owned a one-tenth share in each of the leased properties. They alleged misrepresentation by Teresa in asserting that the estate was the sole owner and that she leased the properties without conformity.
• Additionally, one complaint asserted that the Florencio Sr. estate was distinct from other heirs’ estates, and that the plaintiffs had not received their rightful share from the rental incomes due to Teresa’s failure to account for such proceeds.

Audit, Accounting, and Subsequent Motions

• The Baguio RTC commissioned a team of auditors led by Leticia Clemente to conduct an accounting of the estate’s assets, revealing a total cash accountability of P15,238,066.51 under Teresa’s administration.
• A motion for the distribution of the heirs’ shares and partition of the properties was filed on January 19, 2004, but the intestate court denied it in an Order dated April 13, 2004, stating that it had exclusive jurisdiction over estate matters.
• A subsequent motion for reconsideration by the respondents was also denied by the intestate court in an Order dated June 14, 2012, reaffirming the refusal to allow partition or advance distribution without satisfying certain obligations.

Appeals and the Certiorari Petition

• In view of the denials by the intestate court, respondents filed a petition for certiorari with the Court of Appeals, challenging the Orders dated April 13, 2004, and June 14, 2012.
• The CA, in its Decision dated March 27, 2014, annulled and set aside the challenged Orders and granted the petition, directing the RTC of Baguio City, Branch 3, to partition the disputed Baguio properties among the co-owners.
• Following the CA’s decision, Teresa filed a petition for review on certiorari before the Supreme Court, raising issues regarding the availability of an appeal or other plain, speedy, and adequate remedy, and alleging that the trial court would be violating the Rules of Court if it proceeded further.

Issue:

Availability of Ordinary Remedies

• Whether there is an appeal or other plain, speedy, and adequate remedy in the ordinary course of law available for the respondents, thereby necessitating that they first seek relief from the trial court before resorting to certiorari.

Nature of the Orders and Their Appealability

• Whether the challenged Orders of the intestate court (dated April 13, 2004, and June 14, 2012) were final or interlocutory in nature, and the implications of such characterization for an appeal under Rule 65 of the Rules of Court.

Limitations of Probate Court Jurisdiction

• Whether the intestate (probate) court had the authority to decide on issues of property ownership and co-ownership, especially when such issues involve co-owned property not solely within the estate.
• Whether the exercise of jurisdiction over the disputed properties amounted to a grave abuse of discretion given that the probate court’s jurisdiction is limited to matters incidental to the settlement of the estate.

Appropriateness of Partition in a Probate Setting

• Whether the proper remedy to resolve the dispute over co-ownership and partition of the estate properties is through an action for judicial partition under the Rules of Court rather than through probate proceedings.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)