G.R. No. 213192 - Ignacio vs. Reyes

On July 11, 1967, Angel Reyes and Oliva R. Arevalo filed a Petition for Letters of Administration of the estate of their deceased father, Florencio Reyes, Sr., who died on June 23, 1967, before the then Court of First Instance of Rizal (now RTC of Pasig City, Branch 151).
The petition enumerated the surviving heirs as Oliva, Francisca Vda. de Justiniani, Angel, Amparo R. Avecilla, Ramon Reyes, Teresa R. Ignacio (petitioner), Rosario R. Du, Jose Reyes, Soledad Reyes, Carmelita R. Pastor, and Florencio Reyes, Jr.

Oliva was appointed special administratrix on July 15, 1967, and as regular administratrix on November 23, 1967.
Florencio Jr. replaced Oliva as administratrix in 1982. Teresa became the administratrix on August 8, 1994.

On December 5, 1994, Teresa executed a lease contract over a 398 sq. m. parcel of land in Magsaysay Avenue, Baguio City (Magsaysay property), which the intestate court approved on July 15, 1996.
On September 26, 1996, Teresa was allowed to lease a 646 sq. m. parcel located at Session Road, Baguio City (Session Road property) to Famous Realty Corporation (FRC). The lease was from July 1, 1996 to June 30, 2003, with a monthly rental of ₱135,000.00.
In January 1997, Teresa leased properties located at Loakan Road, Baguio City (Loakan and Military Cut-off properties) to ATC Wonderland, Inc., Gloria de Guzman, and Sonshine Pre-School for ten years, effective September 1, 1996 to August 31, 2006.

On September 25, 2001, respondents Ramon, Florencio Jr., Rosario, Carmelita, and heirs of Amparo, Soledad, Jose, and Angel (plaintiffs) filed three complaints for partition, annulment of lease contracts, accounting, and damages, praying for preliminary injunction against Teresa and the lessees.
Plaintiffs alleged the Florencio Sr. estate and heirs each owned a one-tenth (1/10) interest in the properties and claimed Teresa misrepresented sole ownership and failed to account for rental income.
They also claimed that the Florencio Sr. estate was distinct from the Heirs of Florencio Sr. and the Heirs of Salud.

The Baguio RTC commissioned auditors, led by Leticia Clemente, who reported Teresa had cash accountability of ₱15,238,066.51 as administratrix of the estate.
The Baguio RTC waited for a Request Order from the intestate court concerning distribution of the properties’ net income and partition.
On January 19, 2004, respondents filed a motion before the intestate court to allow distribution of shares and partition of co-owned properties by the Baguio RTC.
The intestate court denied the motion in Orders dated April 13, 2004 and June 14, 2012, asserting exclusive jurisdiction over the estate properties and refusing partition by the Baguio RTC.

Petition for certiorari filed by respondents before the Court of Appeals (CA)

Respondents assailed the intestate court’s Orders denying partition and distribution.
On March 27, 2014, the CA granted the petition, annulled and set aside the orders, and directed the Baguio RTC to partition the Baguio properties among the co-owners.

Teresa filed the instant petition challenging the CA Decision and Resolution.
She argued availability of other remedies, the intestate court’s jurisdiction over the estate properties, and that the Court of Appeals erred in its decision.
Subsequently, Teresa partially conceded that the Magsaysay property is co-owned and not part of the estate proceeding.

Whether there was grave abuse of discretion amounting to lack or excess of jurisdiction in the denial of respondents’ motion for distribution and partition by the intestate court.

Whether the Court of Appeals correctly annulled the intestate court's orders and directed the Baguio RTC to partition the properties.

Whether a petition for certiorari was the appropriate remedy given the nature of the orders assailed (final or interlocutory).

Whether the intestate court had jurisdiction to determine ownership and permit partition of the subject properties.