Facts:

The case involves the intestate estate of the deceased Marcelo de Borja, with Crisanto de Borja serving as the administrator and appellee, while Juliana de Borja is the oppositor and appellant. The proceedings began in 1927 after Marcelo de Borja, a wealthy individual from Pateros, Rizal, passed away without a will. For over twenty years, the estate remained unliquidated and undivided due to the inability of the heirs to agree on a partition plan. The heirs included Francisco de Borja, Quintin de Borja (deceased), Juliana de Borja, and Crisanta de Borja (also deceased). The court appointed commissioners in 1940 to facilitate the partition after numerous failed attempts by the heirs to reach a consensus. On February 8, 1944, the commissioners submitted a project of partition, which was approved by the court despite Juliana de Borja's opposition. Juliana claimed she was not given a fair opportunity to present her case before the commissioners and argued that the partition w...

Facts:

1. Background of the Case:

   • Marcelo de Borja, the richest man in Pateros, Rizal, died intestate in 1927.
   • The intestate estate proceeding was filed in the Court of First Instance, but the estate remained unliquidated and undivided for over 20 years.
   • Two of the four heirs (Quintin de Borja and Crisanta de Borja) died during the trial, and the remaining two (Francisco de Borja and Juliana de Borja) were over 70 years old.

2. Attempts at Partition:

   • Various plans of partition were submitted by the heirs over the years, but none were agreed upon due to "ambition, intolerance, and selfishness."
   • In 1940, the court declared that Marcelo de Borja left four legitimate heirs: Francisco de Borja, Quintin de Borja (deceased), Juliana de Borja, and Crisanta de Borja (deceased).
   • The court required the administrator and heirs to submit a project of partition, but no agreement was reached.

3. Appointment of Commissioners:

   • The court appointed two commissioners, Saturnino David (Provincial Treasurer and ex-oficio Assessor of Rizal) and Severo Abellera (Clerk of Court), to draw up a project of partition.
   • The commissioners submitted their project of partition on February 8, 1944, which was approved by the court despite Juliana de Borja's opposition.

4. Juliana de Borja's Objections:

   • Juliana de Borja appealed the court's approval of the partition, claiming she was not given an opportunity to be heard by the commissioners.
   • She also argued that the partition was contrary to an understanding among the heirs and that she was excluded from the division of a building composed of six apartments.

5. Court's Findings on Objections:

   • The court found Juliana's objections unmeritorious, noting that she had ample opportunity to present her case during the hearings.
   • The partition was deemed fair, with Juliana receiving properties valued at P80,595.05, which was more than the value awarded to other heirs except Crisanta de Borja.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Fairness in Partition:

   • In partition cases, it is not necessary to show specific property given in exchange for excluded shares. It is sufficient if the overall result shows that all heirs received substantially equal shares.

2. Due Process:

   • A party cannot claim denial of due process if they were given ample opportunity to present their case and objections during the proceedings.

3. Policy on Estate Administration:

   • The court emphasized the policy of promptly closing estate proceedings to avoid unnecessary delays and expenses, as stated in Rule 89, Section 15 of the Rules of Court.

4. Judicial Efficiency:

   • The court reiterated its stance against excessive delays in estate proceedings, noting that such delays are detrimental to the heirs and the estate.