G.R. No. L-31979 - Pizarro vs. Court of Appeals

Case Digest (G.R. No. L-31979)
Expanded Legal Reasoning Model

Facts:

Parties and Estate Administration

Petitioner Filomena G. Pizarro is the surviving spouse of the late Aurelio Pizarro, Sr.
The other petitioners—Misael, Aurelio Jr., Luzminda, Delia-Thelma, Rogelio, Virgilio, Rosalinda, Jose Elvin, and Maria Evelyn Pizarro—are the children of the deceased.
Following the death of Aurelio Pizarro, Sr., Special Proceedings No. 1421 (“In the Intestate Estate of the Deceased Aurelio Pizarro, Sr.”) was instituted on September 21, 1965, in the Court of First Instance of Davao, Branch I.
The estate included parcels of land situated along Agdao, J. Palma Gil, and Claro M. Recto Streets in Davao City.
On December 23, 1965, the Court, upon mutual agreement of the parties, appointed Gaudencio A. Corias as the Administrator of the estate.

Initiation and Approval of the Sale of the Agdao Property

On January 11, 1967, the Administrator, through Atty. Regalado C. Salvador, filed a Motion for Authority to Sell the Agdao and Jose Palma Gil properties in order to settle debts of the estate estimated at P257,361.23 (inclusive of inheritance and estate taxes).
The heirs, including Alicia P. Ladisla and Lydia P. Gudani, opposed the Motion, contending that the estate’s obligations were exaggerated and that the sale of a specific lot (13,014 sq. m. in Agdao) would be more than sufficient to settle the debts.
On February 7, 1967, the Court authorized the sale “in the interest of the parties,” noting that a majority of the heirs favored the sale to avoid an extra burden of about P2,000.00 monthly.

Conditional Approval and Subsequent Motions

On February 8, 1967, the Administrator moved for the approval of the conditional sale of the Agdao property to Alfonso L. Angliongto for a total consideration of P146,820.00 payable in six installments with a condition that the vendor eject all occupants by or before July 31, 1967.
The heirs contested the sale by filing a Motion to Set Aside the Order, arguing that they were negotiating an alternative sale with Mr. Benjamin Gonzales for a portion of the property being developed into a theatre, but the Court rejected such motion on February 9, 1967 as “nothing but speculations.”
Further, the heirs sought reconsideration on the basis of being deprived of a more beneficial sale, maintaining that:

The sale was improvident and would cause great prejudice.
No formal determination of the estate's obligations had been made.
The sale’s terms were substantially prejudicial to their interests.

The Court denied this reconsideration on February 20, 1967, affirming that the sale was “more beneficial.”

Sale of Additional Property and Administrative Developments

On February 22, 1967, the Administrator sought authority to sell the Claro M. Recto lot, arguing that proceeds from the Agdao sale were insufficient to settle the estate’s obligations.
The sale on J. Palma Gil Street was unanimously opposed by the heirs. Authority to sell the Claro M. Recto lot was granted on March 6, 1967.
Prior to this, on February 27, 1967, the heirs had moved that the Administrator be removed due to alleged abuse of powers and had requested that Letters of Administration be granted to Filomena Pizarro, also terminating the services of Atty. Salvador.
On March 11, 1967, the Administrator moved to resign, and ultimately on July 13, 1967, he ceased to serve in that capacity.

Filing of the Rescission Case

On June 22, 1967, most of the heirs (except Alicia P. Ladisla and Lydia P. Gudani) filed a Motion for Cancellation or Rescission of the Conditional Contract of Sale of the Agdao property, arguing that:

The sale was unnecessary and prejudicial to their interests.
The alternative sale of the Claro M. Recto property for P370,000.00 would have sufficed to settle the estate’s obligations.
The condition requiring prompt ejectment of countless tenants (nineteen occupants) was impracticable, and the vendee had defaulted on subsequent payments.

The Court, in its July 3, 1967 Order, denied the rescission motion, holding that the relief was beyond its power and that the proper remedy would be to file a separate action in a competent Court.
Subsequently, without waiting for the resolution of their reconsideration motion, on October 5, 1967, the heirs (again, save for Alicia P. Ladisla and Lydia P. Gudani) filed a verified Complaint (Civil Case No. 5762, the “Rescission Case”) seeking:

Cancellation of the authority to sell.
Rescission and annulment of the deed of sale.
Damages and a preliminary injunction to prevent further actions by the Angliongto spouses.

Attached to the Complaint was a letter from Atty. Raul Tolentino indicating that a sum of P58,728.00, paid by Alfonso Angliongto and deposited by court order in favor of the estate, had been dishonored due to a stop-payment order.

Trial Court Dismissal and Subsequent Appeals

On April 10, 1968, Judge Manases G. Reyes of the Court of First Instance (Branch III) dismissed the Rescission Case on the ground that reviewing the actuations of a coordinate branch (the Probate Court) was beyond its jurisdiction, and because a Motion for Reconsideration was pending before the Probate Court.
The plaintiffs’ Motion for Reconsideration was denied on October 10, 1968.
While the Rescission Case was pending, the Angliongto spouses themselves filed a separate Civil Case No. 5849 for Damages against the heirs.
On November 25, 1968, the petitioners elevated the matter to the Court of Appeals via a Petition for Certiorari and Mandamus with Prohibition and Preliminary Injunction, charging Judge Reyes with grave abuse of discretion.
On February 11, 1970, the Court of Appeals dismissed the Petition on several grounds, including that the trial Court had no power to review the actuation of a coordinate branch, that the appropriate remedy was appeal, and that the petition did not meet the certification requirements of Section 1, Rule 65 of the Rules of Court.
In a subsequent manifestation filed on March 29, 1976, the petitioners disclosed that the Angliongto spouses had mortgaged the Agdao property to the Development Bank of the Philippines, later subdividing it and selling a major parcel, thereby allegedly transferring title to third parties.

Jurisdictional and Procedural Controversies

The primary issue emerged as whether the trial Court had jurisdiction to review matters concerning the Rescission Case given that the Probate Court’s actions were deemed non-reviewable.
The petitioners contended that the factual cause of action underlying the Rescission Case—namely, the failure of the vendees to pay the full purchase price—was within the trial Court’s jurisdiction.
A secondary contention was whether the dispositional remedy of Certiorari was proper given that appeal as a remedy was available but would prove inadequate and overly protracted, thus justifying prompt judicial intervention to protect the heirs’ interests.

Issues:

Jurisdictional Issue

Whether the trial Court (Branch III) had jurisdiction to entertain the Rescission Case, given that it sought to review or intervene in the acts of a coordinate branch (the Probate Court, Branch IV).

Adequacy of the Remedy

Whether the filing of the Certiorari petition was proper despite the general rule that an appeal serves as the ordinary remedy, particularly upon the ground that appeal would be too protracted and ineffectual to prevent imminent harm to the petitioners.

Validity of the Sale and Grounds for Rescission

Whether the Agdao property sale, especially in light of the alleged non-payment of part of the purchase price and impracticable conditions (e.g., ejectment of tenants), should be rescinded.

Compliance with Procedural Requirements

Whether the non-presentation of a certified true copy of the Order of April 10, 1968, adversely affected the petition given the requirements under Section 1, Rule 65 of the Rules of Court.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

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Case Digest (G.R. No. L-31979) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. L-31979) Expanded Legal Reasoning Model

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Case Digest (G.R. No. L-31979)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. L-31979)
Expanded Legal Reasoning Model