G.R. No. 167979 - Uy vs. Court of Appeals

Jose K.C. Uy died intestate on August 20, 1996, survived by his spouse and five children including petitioner Wilson S. Uy.
Special Proceedings No. 97-241 was instituted on February 18, 1997, and Lilia HofileAa was appointed as special administrator of the estate.
Petitioner moved for reconsideration seeking issuance of letters of administration in his favor.
On June 9, 1998, Lilia HofileAa’s appointment was revoked; letters of administration were granted to petitioner, who took oath on June 23, 1998.

On February 17, 1999, Johnny K.H. Uy (respondent), brother and creditor of deceased, moved to intervene and be appointed administrator in lieu of petitioner.
Trial court initially denied the motion to intervene but on March 16, 2000, reconsidered and appointed Johnny as co-administrator, retaining petitioner as administrator.
Petitioner’s motion for reconsideration was denied.

Petitioner moved that Johnny bring into the estate properties belonging to the deceased; the court granted the motion.
Dissatisfied with Johnny’s compliance, petitioner moved for his removal as co-administrator; the trial court denied the motion finding substantial compliance.
Petitioner appealed to the Court of Appeals via petition for certiorari; petition was dismissed, and resolution denying reconsideration was affirmed.

Trial court and Court of Appeals acted without jurisdiction or grave abuse of discretion by appointing a co-administrator while he remains the incumbent administrator whose appointment is final and unrevoked.
The appointment violated rules on order of preference and appointed a person alien to the estate with conflicting interests and unsuitable character.
Court of Appeals deprived him of constitutional rights of due process and right to petition by not resolving issues on res judicata and appointment stability.

Whether the trial court acted with grave abuse of discretion or without jurisdiction in appointing Johnny K.H. Uy as co-administrator while petitioner was the incumbent administrator with a final appointment.
Whether the Court of Appeals violated petitioner’s constitutional rights to due process and right to petition the government for redress of grievances by not resolving the substantive issues raised.