G.R. No. 207146 - Spouses Williams vs. Zerda

The case involves the intestate estate of Luz Garcia, daughter of Juan Garcia Sanchez, who died intestate.
In a previous administration proceeding (Special Proceedings No. 3475) in the Court of First Instance of Tarlac, the surviving spouse, Leona Pasion Vda. de Garcia, was appointed judicial administratrix of Juan Garcia Sanchez’s estate.
The legitimate forced heirs of Juan Garcia Sanchez include his legitimate children—Juan Garcia, Jr., Patrocinio Garcia, and Luz Garcia—as well as the surviving spouse.

Luz Garcia, one of the heirs of Juan Garcia Sanchez, was married to Pablo G. Utulo (the applicant/appellee).
During the pendency of the administration proceedings concerning Juan Garcia Sanchez’s estate, Luz Garcia died in Tarlac.
At the time of her death, Luz Garcia left no legitimate descendants; her forced heirs were her mother (the oppositor/appellant, Leona Pasion Vda. de Garcia) and her husband, Pablo G. Utulo.

After Luz Garcia’s death, Pablo G. Utulo initiated a petition in the same court (Special Proceedings No. 4188) seeking the judicial administration of his deceased wife’s property.
In his petition, the applicant asserted that the only heirs to his wife’s estate were he himself and his mother-in-law, Leona Pasion Vda. de Garcia, contending that the entire property consisted of the share due to Luz Garcia as forced heir from her father’s intestate estate.

Leona Pasion Vda. de Garcia (the oppositor/appellant) objected to both the administration of Luz Garcia’s property and the appointment of Pablo G. Utulo as judicial administrator.
She argued that, given the absence of indebtedness in the estate, judicial administration was unnecessary.
The oppositor further claimed that if judicial administration were required, her rights as forced heir entitled her to be named the administratrix due to her superior legal interest.

Following the completion of the required publications and a trial held in the Court of First Instance, an order was issued on August 28, 1936, appointing Pablo G. Utulo as the judicial administrator of Luz Garcia’s property.
The oppositor thereafter appealed that order by filing the requisite appeal record, setting the stage for the issues resolved in this case.

Whether the property left by Luz Garcia, as a forced heir from the intestate estate of her father, requires judicial administration under the admitted facts.
Whether the absence of debts and the immediate transmission of ownership to the heirs under the Civil Code removes the need for appointing an administrator.

Whether the oppositor (Leona Pasion Vda. de Garcia) possesses a better right to be appointed administrator over the applicant (Pablo G. Utulo).
Whether the appointment of the applicant as administrator is justified given the familial relations and legal positions of the parties.