G.R. No. 124715 - Lim vs. Court of Appeals

Petitioner Rufina Luy Lim is the surviving spouse of the late Pastor Y. Lim, who died intestate on June 11, 1994. She filed on March 17, 1995 a joint petition for administration of his estate (SP Q-95-23334) before the Regional Trial Court (RTC) of Quezon City, Branch 93, as probate court.
Private respondents Auto Truck TBA Corporation, Speed Distributing, Inc., Active Distributors, Inc., Alliance Marketing Corporation and Action Company, Inc. are Philippine corporations holding Torrens-titled real properties allegedly included in the decedent’s estate inventory.

June 8, 1995 – The RTC granted respondents’ motions to lift lis pendens and exclude certain Torrens-titled properties from the estate inventory.
July 4, September 12 and September 15, 1995 – Petitioner secured orders setting aside the June 8 exclusion order, reinstating lis pendens, including the disputed properties in the inventory and compelling production of bank records in the names of the decedent and the corporations. The court also appointed petitioner and co-administrators.
Respondents filed a certiorari petition with urgent injunction before the Court of Appeals (CA).
April 18, 1996 – The CA nullified the July 4 and September 12 orders and partially nullified the September 15 order insofar as it concerned respondents’ corporate bank records.
Petitioner elevated the case to the Supreme Court via Rule 45, assigning as error the CA’s reversal of the probate court’s provisional inclusion of the corporations and its bank-record order.

Whether a corporation, as a juridical entity separate from its stockholders, may be included in the inventory of a deceased person’s estate and its assets subjected to probate proceedings.
Whether the RTC, acting as a probate court with limited jurisdiction, properly exercised provisional authority to (a) include Torrens-titled properties registered in corporate names in the estate inventory and (b) compel production of corporate bank records.
Whether the CA erred in nullifying the RTC’s orders in light of the Rules of Court on probate proceedings and settled jurisprudence on Torrens titles and corporate veil piercing.