G.R. No. 118295 - Tanada vs. Angara

Gloria Tirol died testate on October 10, 1991, survived by her husband Roberto Tirol, Sr. and their six children: Ruth, Cecilia, Marilou, Ciriaco, Anna Maria, and Roberto Jr.
Roberto Jr. died intestate on April 16, 1995, survived by his four children: Martin (the petitioner), Zharina, Francis, and Daniel. His marriage to Cecilia Geronimo had been annulled before his death.
Roberto Sr. died testate on January 8, 2002, survived by Ruth, Cecilia, Marilou, Ciriaco, Anna, and the four grandchildren from Roberto Jr.

On April 2, 2002, petitioner Martin, Cecilia, and Ciriaco filed before RTC-218 a petition to probate the wills of Gloria and Roberto Sr. Ruth and Marilou intervened later.
RTC-218 admitted the wills to probate and designated petitioner Martin as Administrator of the estates of Gloria and Roberto Sr.
On February 25, 2011, respondent Sol Nolasco, alleging she was the surviving spouse of Roberto Jr. (married July 15, 1994), filed a Motion for Intervention in the probate proceedings, claiming interest as compulsory heir under Article 887 of the Civil Code, asserting entitlement to Roberto Jr.’s share of Gloria’s estate.
Petitioner Martin and several other heirs opposed Sol’s motion, contesting her legal interest and validity of her claimed marriage on ground of bigamy.
Respondent Sol also filed a motion for intervention before RTC-101 in the intestate estate settlement of Roberto Jr., which was granted by RTC-101 (Order dated May 8, 2012). Zharina was appointed Administratrix of Roberto Jr.’s estate.

On June 27, 2013, RTC-218 issued an Omnibus Resolution denying Sol's motion for intervention and claim-in-intervention, ruling she had no legal interest in the probate case.
Sol’s motion for reconsideration was denied on October 27, 2013.
Sol filed a petition for certiorari with the Court of Appeals (CA) to challenge RTC-218’s rulings, which Martin opposed.

On April 27, 2016, CA granted Sol’s petition, annulled and set aside RTC-218’s Omnibus Resolution and Order, and ordered RTC-218 to admit Sol’s intervention and claim-in-intervention.
CA ruled Sol, as widow of Roberto Jr., had a legal interest in the probate of Gloria and Roberto Sr.’s estates because the extent of Roberto Jr.’s share remained undetermined.
Petitioner Martin moved for reconsideration, arguing Sol’s rights can be fully protected in the intestate estate proceeding before RTC-101.
CA denied the motion for reconsideration on February 23, 2017, without addressing this argument.

Whether the CA erred in finding respondent Sol to be a compulsory heir of Gloria and Roberto Sr. under Article 887 of the Civil Code by virtue of being the widow of Roberto Jr.
Whether the CA erred in failing to consider that respondent Sol’s rights and interests in Roberto Jr.’s estate can be fully protected in the intestate estate proceedings (Spec. Proc. No. Q-95-25497) before RTC-101, making her intervention in the probate proceedings unnecessary.
Whether the CA erred in not giving due consideration that respondent Sol’s intervention would undo 14 years of resolved incidents in the probate case and cause further delay.
Whether the CA erred in applying the rulings in Alfelor v. Halasan and Uy v. Court of Appeals.