G.R. No. 157549 - Halley vs. Printwell, Inc.

On July 13, 1965, petitioners Adela Ongsiaco Vda. de Clemena (the widow) and her daughters Lyda, Alicia, and Olga Clemena, filed a special civil action for certiorari and prohibition.
The petition sought to set aside the order issued by Judge Pedro C. Navarro of the Court of First Instance of Rizal, Branch II, which denied the motion to dismiss filed by respondent Agustin Engracio Clemena.

A pending case for partition, inventory, accounting, and delivery of shares had already been instituted in the Court of First Instance of Rizal, where respondent Agustin Engracio Clemena, as plaintiff, filed his motion.
In that separate action, Agustin sought the following:

An order directing petitioner Adela to submit a true inventory of the conjugal properties.
An accounting of the income from the conjugal and her paraphernal properties, which she controlled due to the deceased’s illness.
A project for the partition of the estate and the delivery of his legal share as an alleged illegitimate child.

The respondent judge had denied the petitioners’ motion to dismiss on the ground that:

The partition suit originated before the special proceeding for settlement and distribution of the estate filed in the Court of First Instance of Manila.
The issues raised in the partition suit (inventory, accounting, and inheritance claims) were distinct from the estate proceedings.

Petitioners argued that the Court of First Instance of Manila, handling the intestate proceedings, had exclusive jurisdiction over the settlement and distribution of the deceased’s estate.
They contended that the respondent judge in Rizal should have dismissed the partition case on jurisdictional grounds, thus avoiding duplication of proceedings.

In a decision rendered on August 22, 1968, Justice J. B. L. Reyes, in the case Vda. de Clemena v. Clemena (G.R. No. L-24845), held that:

The action of an alleged illegitimate child, who was not a natural child and was over 21 at the time of the deceased’s death, to secure a judicial declaration of paternity was barred by the time limits prescribed under Article 285 of the Civil Code.
Such a declaration, if allowed, would upset the classification scheme for children’s rights under the Civil Code, placing the illegitimate (not natural) child on an equal footing with legitimate children—the latter requiring an express statutory provision.

The Supreme Court, relying on this earlier decision, had already declared respondent Agustin Engracio Clemena to be without legal interest in the estate.

With Agustin being judicially declared as without legal interest, his continued participation in the partition suit was rendered moot.
This led petitioners to seek a writ of certiorari and prohibition to set aside the lower court’s order refusing to dismiss the partition case and to restrain the further conduct of the proceedings.

Whether the Court of First Instance of Rizal had jurisdiction over the pending partition suit, and whether its refusal to dismiss the case was proper given the existence of the separate intestate proceedings in Manila.
Whether respondent Agustin Engracio Clemena, as an alleged illegitimate (not natural) child who was over 21 at the time of the deceased’s death, possessed any legal interest in the estate as to justify his participation in the partition suit.
Whether the issuance of the order refusing to dismiss the partition case amounted to a grave abuse of discretion, especially in light of the existing jurisprudence regarding the filing of paternity suits by illegitimate children.