Case Digest (G.R. No. 216109)
Facts:
Saphia Mutilan, Sauda Mutilan, and Mohammad M. Mutilan v. Cadidia Mutilan (known recently as Cadidia Imam Samporna), G.R. No. 216109, February 05, 2020, Supreme Court Third Division, Leonen, J., writing for the Court.Petitioners Saphia, Sauda, and Mohammad M. Mutilan are heirs of the deceased Mahid M. Mutilan; respondent Cadidia Imam Samporna (respondent) was Mahid’s surviving wife who acquired two parcels of land in 1999 by two notarized Deeds of Absolute Sale from Rodolfo “Boy” Yu Diator (acting for Alice Yu Diator). Cadidia executed affidavits asserting the purchase consideration came from her separate funds. Titles in her name were later issued by the Register of Deeds of Marawi City.
Mahid died in a vehicular accident on December 6, 2007. On April 8, 2008, Saphia filed a petition for judicial settlement of Mahid’s estate before the Shari’a District Court, Fourth Shari’a Judicial Court of Marawi City. The Shari’a District Court issued Letters of Administration appointing Cadidia administratix, approved an inventory that excluded the two parcels titled in Cadidia’s name (Omnibus Order, October 15, 2008), and on January 30, 2009 quashed a writ of possession over those parcels.
On March 19, 2009 petitioners filed a Complaint in the Regional Trial Court (RTC) of Marawi City seeking annulment of the Deeds of Absolute Sale and cancellation of the titles, alleging Mahid had in fact bought the properties. Cadidia answered, raising affirmative defenses. The RTC (Presiding Judge Antonio M. Guiling) dismissed the Complaint on June 23, 2010, finding petitioners were not parties in interest to the sales, that they failed to implead Diator (the seller) as an indispensable party, and that they had engaged in forum shopping by invoking the RTC after the probate proceeding.
Petitioners appealed to the Court of Appeals (CA-G.R. CV No. 02333-MIN). In a March 17, 2014 Decision the Court of Appeals affirmed: it held that the Shari’a District Court (acting as probate court) had jurisdiction to decide ownership because the interested parties were all heirs and no third-party rights were impaired; it characterized petitioners’ resort to the RTC after the probate court’s ruling as forum shopping; it held petitioners were not real parties in interest because they were not parties to the Deeds of Absolute Sale; and it found failure to implead indispensable parties fatal. The CA denied reconsideration in its December 2, 2014 Resolution.
Petitioners filed a Petition for Review on Certiorari under Rule 45 with this Court on February 6, 2015, challenging the CA rulings. They argued the probate court’s exclusion was provisional only, that their rights as Mahid’s heirs would be prejudiced and thus they coul...(Pro-only)
Issues:
- Are the Shari’a District Court’s findings excluding the parcels from the deceased’s estate binding on the other heirs such that they cannot file a separate civil action to determine ownership?
- Are petitioners, heirs only of the deceased husband and not parties to the Deeds of Absolute Sale, real parties in interest entitled to seek annulment of those Deeds?
- Does petitioners’ failure to implead indispensable partie...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)