Case Digest (G.R. No. 181186)
Facts:
- The petitioner is Siguion Reyna Montecillo & Ongsiako Law Offices (SRMO).
- The respondents include Hon. Norma Chionlo-Sia, Presiding Judge of Branch 56 of the RTC of Lucena City, and the Testate Estate of Susano Rodriguez.
- Remedios N. Rodriguez initiated intestate proceedings for her deceased husband’s estate, docketed as Sp. Proc. No. 4440.
- The RTC denied her request for a widow's allowance on August 8, 1983.
- The Court of Appeals reversed this decision, granting her a monthly allowance of P3,000.00 effective August 1982.
- On February 29, 1988, Remedios sold her rights in the estate to Remigio M. Gerardo for P200,000.00 and granted him a special power of attorney.
- Gerardo designated SRMO as his substitute attorney-in-fact.
- After the Court of Appeals' decision became final, SRMO filed a motion for the payment of the widow's allowance, totaling P315,000.00, which the estate remitted to SRMO.
- In 2002, Remedios questioned the RTC's approval of the estate partition and denied the Deed of Sale but later withdrew her motion.
- The RTC ordered SRMO to reimburse the estate P315,000.00, stating the sale of inheritance was undisclosed and the widow's allowance was personal.
- SRMO's motion for exemption from reimbursement was denied, leading to a petition for certiorari to the Court of Appeals, which was denied due to lack of standing.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, setting aside the decisions of the Court of Appeals and the RTC's orders for SRMO to reimburse the estate.
- The Court ruled that SRMO had standing to fil...(Unlock)
Ratio:
- The Supreme Court noted that while certiorari is generally limited to parties in original proceedings, exceptions apply.
- SRMO was not a passive participant; it was directly ordered to reimburse the estate, creating personal liability.
- The widow's allowance was received by SRMO as an agent for Gerardo, not for its own benefit.
- The RTC's order to reimburse SRMO was unusual, as it typically addresses the parties involved rather than their counsel. ...continue reading
Case Digest (G.R. No. 181186)
Facts:
The case involves the petitioner, Siguion Reyna Montecillo & Ongsiako Law Offices (SRMO), and the respondents, Hon. Norma Chionlo-Sia, in her capacity as Presiding Judge of Branch 56 of the Regional Trial Court (RTC) of Lucena City, and the Testate Estate of the deceased Susano Rodriguez, represented by the Special Administratrix. The events leading to this case began when Remedios N. Rodriguez, the widow of Susano J. Rodriguez, initiated intestate proceedings for the settlement of her deceased husband's estate, which was docketed as Sp. Proc. No. 4440 in the RTC of Lucena City. During these proceedings, Remedios sought a widow's allowance, which the RTC denied in an order dated August 8, 1983. The Court of Appeals later reversed this decision, granting her a monthly widow's allowance of P3,000.00 effective August 1982.
On February 29, 1988, while the case was still pending, Remedios executed a Deed of Sale of Inheritance, selling all her rights and interests in the estate to Remigio M. Gerardo for P200,000.00. Subsequently, she granted Gerardo a special power of attorney, allowing him to receive any property or funds due to her. Gerardo then designated SRMO as his substitute attorney-in-fact. After the Court of Appeals' decision became final, SRMO filed a motion with the RTC for the payment of the widow's allowance, which amounted to P315,000.00. The estate remitted this amount to SRMO.
In 2002, Remedios filed a motion questioning the RTC's approval of the estate partition and denied the execution of the Deed of Sale. Before the RTC could resolve this motion, Remedios withdrew it. However, the RTC, in an order dated August 21, 2003, directed SRMO to reimburse the estate the amount of P315,000.00. SRMO contended that it was merely enfo...