G.R. No. 203770 - Mayor vs. Tiu

On May 25, 2008, Rosario Guy-Juco Villasin Casilan died, leaving a holographic will naming her sister Remedios Tiu and niece Manuela Azucena Mayor as executors; they filed a petition for probate of the will and issuance of letters testamentary with RTC-Br. 9 in Tacloban City (Sp. Proc. No. 2008-05-30).
On May 29, 2008, respondent Damiana Charito Marty, claiming to be Rosario’s adopted daughter, filed for letters of administration before RTC-Br. 34 (Sp. Proc. No. 2008-05-32), but the petition was not given due course due to the pending probate proceedings.

June 12, 2008: The court found the probate petition sufficient in form and substance; set the case for hearing. Marty filed an urgent manifestation seeking preservation of estate assets (inventory, freeze of bank accounts, deposit of rentals, lock-up of Primrose Hotel).
July 2008: Remedios and Manuela opposed, asserting Marty was not adopted (per clerk’s certification) and that properties claimed by Marty belonged to Primrose Development Corporation, a separate juridical entity. Marty replied, citing a 1981 CFI Leyte order piercing Primrose’s corporate veil.

January 14, 2009: The probate court granted Marty’s motion, appointed the OIC clerk as special administrator, applied the corporate-veil doctrine, froze bank accounts, and directed tenants (Mercury Drug, Chowking) to deposit rentals with the court.
March 27, 2009: The court denied Remedios and Manuela’s motion for reconsideration; granted their motion for inhibition; re-raffled the case to RTC-Br. 6.
October 16, 2009: The Court of Appeals reversed the January 14, 2009 orders (except as to properties specifically belonging to the estate), holding Primrose distinct from Rosario’s estate and that the probate court lacked jurisdiction to adjudicate title or apply piercing of the corporate veil.

November 17, 2009: RTC-Br. 6 partially revoked orders affecting Primrose’s day-to-day operations; appointed a new special administrator; upheld inventory of estate properties.
September 24, 2010: Marty filed an Omnibus Motion in RTC-Br. 6 for accounting of estate assets, deposit/consignment of rentals, and prohibition of disbursements without court approval.
January 20 & June 10, 2011: RTC-Br. 6 granted the Omnibus Motion, directing petitioners to render accounting, deposit rentals, and empowering the special administrator to pursue recovery actions; denied petitioner’s motion for reconsideration.
October 5, 2011 & September 24, 2012: The Court of Appeals dismissed petitioner’s Rule 65 certiorari petitions for procedural infirmities (service by registered mail, failure to state material dates, uncertified true copies, defective verification and certification against forum-shopping).
June 14, 2013 & October 14, 2013: The Supreme Court issued a TRO and later made it permanent, restraining RTC-Br. 6 from implementing its orders as to Primrose’s corporate properties.

Whether the Court of Appeals erred in dismissing petitioner’s certiorari petitions under Rule 65 for alleged procedural defects (proof of service by registered mail, failure to state material dates, absence of certified true copies, defective verification and certification against forum-shopping).
Whether RTC-Br. 6 exceeded its jurisdiction and violated Primrose Development Corporation’s rights by applying the doctrine of piercing the corporate veil and ordering the deposit of corporate rentals, comprehensive accounting, and inventory of corporate assets in the probate proceedings.