G.R. No. L-27860 - Philippine Commercial and Industrial Bank vs. Escolin

Petitioner-Appellant: Philippine Commercial and Industrial Bank, acting as the administrator of the testate estate of Charles Newton Hodges.
Respondents:

The Honorable Venicio Escolin, Presiding Judge of the Court of First Instance of Iloilo, Branch II.
Avelina A. Magno, along with others including administrators and heirs involved in the testate estates of Linnie Jane Hodges and Charles Newton Hodges.

The litigation concerns separate testate estates—the estate of the late Linnie Jane Hodges (in SP. PROC. NO. 1307) and that of the late Charles Newton Hodges (in SP. PROC. NO. 1672)—which have been pending judicial settlement for an extended period (over 18 years since Linnie Jane Hodges’ death on May 23, 1957).

Petitioner-Appellant filed a motion for reconsideration followed by a supplemental motion for reconsideration in connection with the Court’s previous decision dated March 29, 1974.
Additional motion for modification was filed by Joe Hodges and other heirs of Charles Newton Hodges regarding the prior decision on the segregation and management of the estate properties.
Respondent-Appellee Avelina Magno filed a motion for the assessment of damages, alleging losses to herself and to the estate of Linnie Jane Hodges caused by a preliminary injunction that had been lifted by an earlier resolution (dated September 8, 1972).

The Court recognized the substantial value of the subject estates and the undue delay in the payment of corresponding taxes.
A critical element of the Case focuses on the need to effectuate an expedient finalization of the inventories of the estates, given the mounting public and administrative pressure, including the directive to dispose of the properties in favor of Filipinos before May 27, 1976.
The earlier decision (March 29, 1974) provided for a physical segregation and separate administration of the community properties (one-fourth exclusively for respondent and one-fourth jointly, with the remainder administered solely by the petitioner), but the urgency of the case raised issues on whether such segregation could be practically implemented before resolving the inventories and other pending matters.

The Court, resolved unanimously enjoining the parties to expedite the submission of inventories (within thirty days) and to resolve outstanding issues leading to the closure of proceedings within three months from notice.
Several Justices, including Acting C.J. Castro, Ferrando, Munoz Palma, Aquino, and Martin, concurred with the resolution.
Justice Teehankee authored a separate concurring opinion, emphasizing:

The necessity of terminating the long-drawn proceedings promptly.
His view that the directive for expediting the closure of the estate matters effectively superseded the earlier decision on the segregation and separate administration of the estates.

Justices Makasiar and Antonio joined in the concurring separate opinion, whereas other members (Makalintal, C.J., Esguerra, and Concepcion Jr., JJ.) were on leave.

Whether the Court should grant the motions for reconsideration and the supplemental motion for reconsideration put forward by the petitioner-appellant.
Whether the modification motion filed by Joe Hodges and other heirs of Charles Newton Hodges should alter the earlier ruling on the segregation and administration scheme of the estates.

Whether respondent-appellee Avelina Magno’s motion for the assessment of damages—based on the losses incurred from the preliminary injunction—should be granted.
Determination of the appropriate method and scope for such assessment, subject to further appeal and review.

How to reconcile the need for a fast-track resolution of the estate proceedings with the previously ordered segregation of community properties and separate administration.
Whether the directive to finalize inventories within thirty days and close the proceedings within three months should override the earlier decision on the physical segregation and distribution of the estate interests.

The handling of residual issues such as the questions of renvoi (referral back to another jurisdiction or body) and renunciation within the estate proceedings.
The role of the respondent court and the new judge in ensuring that these remaining issues are resolved expeditiously to avoid further complications and expenses.