G.R. No. L-19064 - IN RE: Torres vs. Torres

On January 4, 1961, Alberto S. Torres filed a petition in the Court of First Instance of Rizal (Pasay branch) seeking letters of administration for the intestate estate of his mother, Paz E. Siguion Torres, who died on December 18, 1959.
The petition asserted that the decedent left an estate comprising properties with an aggregate value of approximately P300,000.00.
Petitioner maintained he was unaware of any debts or obligations incurred either by the decedent or her estate.

Conchita Torres, one of the heirs, opposed the petition by asserting that an extrajudicial partition and settlement had already been entered into by all heirs on January 27, 1960, in accordance with Section 1 of Rule 74 of the Rules of Court.
The extrajudicial partition deed explicitly stated:

The parties involved were the only legitimate surviving children of Paz E. Siguion Torres.
The decedent died without a will and left no debts.
The estate was to be divided by maintaining a co-ownership of the properties in defined undivided shares for each heir.

In a supplemental answer to the opposition, the petitioner introduced two new issues:

The alleged existence of a P50,000.00 debt from third persons against the estate.
The assertion that there were properties of considerable value not included in the extrajudicial partition.

The petitioner argued that these points highlighted an inability among the heirs to reach a proper physical division of the properties, thereby necessitating court intervention.
It was also noted that the petitioner offered to amend the petition before presentation of evidence.

On July 21, 1961, the lower court dismissed the petition, relying on the fact that the extrajudicial partition and settlement already executed by the heirs was sufficient to settle the estate’s administration.
The dismissal was partially based on the observation that the supplemental allegations regarding the alleged debt and omitted properties were not detailed or verified under oath.

Petitioner-appellant, Alberto S. Torres, proceeded with an appeal against the lower court’s dismissal.
The case centered on whether extrajudicial partition under Section 1, Rule 74 of the Rules of Court precludes the necessity for the special proceeding of administration, despite allegations of unsettled issues regarding the estate.

Whether the existence of a duly executed extrajudicial partition and settlement among all heirs nullifies the need for filing a separate administration proceeding for the estate.
Whether such an extrajudicial settlement, under Section 1, Rule 74, is sufficient to address both the division of the assets and any potential disagreements over physical partition.

Whether the unverified supplemental allegation of an existing P50,000.00 debt from third persons against the estate constitutes a valid cause for instituting an administration proceeding.
Whether the reference to properties not included in the extrajudicial partition, lacking specific details and verification, justifies court intervention in the estate settlement process.