Title
Maningat vs. Castillo
Case
G.R. No. L-74
Decision Date
Dec 8, 1945
In the Philippine case of Maniñgat v. Castillo, the Supreme Court affirms the probate court's jurisdiction to settle conflicting claims regarding subrogation in the estate of Gavino de Jesus, denying the petitioners' request for certiorari and mandamus.
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Case Digest (G.R. No. L-74)

Facts:

  • The case involves conflicting claims regarding subrogation in the estate of Gavino de Jesus.
  • The petitioners, Mateo Maniñgat and the spouses Eugenio Pantoja and Leona Baltazar, purchased the interests of the heirs Demetrio, Elena, and Maria de Jesus.
  • The petitioners filed motions in the Court of First Instance of Batangas for the approval of the sales and their subrogation to the rights of their respective vendors in the settlement of the estate.
  • Sixto de Jesus, as an administrator and coheir of the deceased, opposed the motions and filed a countermotion, claiming the right to repurchase the interests purchased by the petitioners under Article 1067 of the Civil Code.
  • Judge Modesto Castillo of the probate court found that the offer to repurchase had been made within the period provided by law and ordered the petitioners to resell the interests to Sixto de Jesus.
  • The petitioners filed a motion for reconsideration, which was denied by Judge Iigo S. Daza.
  • The petitioners brought the case to the Supreme Court through a petition for certiorari and mandamus.

Issue:

  • (Unlock)

Ruling:

  • The probate court indeed has jurisdiction to settle the conflicting claims regarding subrogation...(Unlock)

Ratio:

  • The main function of a probate court is to settle and liquidate the estates of deceased persons, including determining the heirs and their respective shares.
  • In this case, the petitioners claimed the right to be subrogated to the rights of the heirs they purchased from, while Sixto de Jesus claimed the same right under Article 1067 of the Civil Code.
  • Since the estate was still in the process of administration and settlement, it was within the jurisdicti...continue reading

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