G.R. No. 178145 - Mariano vs. People

Alberto C. Lavides, the petitioner, initiated a guardianship proceeding on April 5, 1971, before the respondent, City Court of Lucena, Branch I, seeking guardianship over the person and property of his seven minor children: Cecilia, Rebecca, Florida, Raphael, Rodolfo, Luisito, and Teodoro—all surnamed Lavides.
The petition alleged that the estate of the deceased wife (mother of the minors) was worth a total of P35,000.00, implying that each minor’s individual share amounted to P5,000.00.

Despite the unsolved settlement of the deceased’s estate, the petitioner was appointed and qualified as judicial guardian on May 10, 1971.
On June 23, 1971, the then-presiding Judge Filemon Juntereal authorized, upon motion, the extra judicial settlement of the estate, including the sale of a portion represented by shares of stock.
Petitioner executed the extra judicial settlement and sold the shares on August 28, 1971, for the sum of P64,512.00.

On November 22, 1978, while a motion for confirmation and approval of a Deed of Exchange Agreement dated November 18, 1978 was pending, the respondent court, now presided by Judge Jose J. Parentela, Jr., reviewed the case records.
The court discovered that the undivided estate was valued at P35,000.00 and consequently dismissed the petition for guardianship in an Order dated December 5, 1978, on the ground of lack of jurisdiction.
In that same order, the appointment of petitioner as guardian was revoked and all proceedings taken prior to the dismissal were annulled.
Petitioner subsequently filed a motion for reconsideration, which was denied by the court in its Order dated December 27, 1978.

The controversy centers on whether the jurisdiction of the respondent city court in guardianship petitions is determined by the total value of the decedent’s estate or by the individual share of each minor child.
Petitioner contended that since there are seven minors, the value attributed to each minor—P5,000.00—is well within the jurisdictional amount prescribed for the city court under Section 1, Rule 92 of the Revised Rules of Court.
Conversely, the respondent city court relied on the aggregate value of P35,000.00 to assert that the petition was outside its jurisdiction.
An additional issue raised was whether the Revised Rules of Court, effective January 1, 1964, nullified the doctrine established in Delgado vs. Gamboa (G.R. No. L-14326, February 28, 1962) regarding the concurrent jurisdiction of inferior courts and the Court of First Instance in guardianship cases.

Is the jurisdiction of the respondent city court over a petition for general guardianship determined by the total value of the deceased’s estate or by the individual share attributable to each minor child?

Has the promulgation of the Revised Rules of Court (effective January 1, 1964) overruled the doctrine established in Delgado vs. Gamboa regarding the concurrent jurisdiction of inferior courts and the Court of First Instance in guardianship cases?