Case Summary (G.R. No. 244542)
RTC Ruling
Petitioners later sued for annulment of the Deed, alleging it covered the entire estate rather than only Federico’s half share. On May 17, 2016, the Regional Trial Court, Branch 19, Digos City, rendered judgment declaring the Deed valid. The RTC held that the extrajudicial settlement and special powers of attorney conferred full ownership upon the petitioners, who were thus free to convey the properties.
CA Ruling
On June 29, 2018, the Court of Appeals declared the RTC judgment void for lack of jurisdiction, citing Rule 73, Sec. 1: the court first taking cognizance of the estate settlement (CFI, Branch 5) had exclusive jurisdiction. The CA dismissed the complaint without prejudice. Its January 16, 2019 resolution denied petitioners’ motion for reconsideration.
Jurisdictional Issue and Analysis
The Supreme Court applied the 1987 Constitution and relevant statutes to distinguish jurisdiction from venue. Jurisdiction over probate matters lies with the Court of First Instance (now RTC) by law (Judiciary Act of 1948, Sec. 44[e]; R.A. 7691). Rule 73, Sec. 1 regulates venue—i.e., which court in which province—but does not divest courts of jurisdiction. The CA mischaracterized venue as jurisdiction and erroneously voided the RTC judgment. Moreover, Teodora’s exclusive properties were no longer under probate administration at the time of sale; questions of ownership fall outside the limited jurisdiction of a probate court. Hence RTC, Branch 19, validly adjudicated the dispute over ownership and contractual rights.
Validity of the Deed of Sale
Under Article 1370 of the Civil Code and the parol evidence rule (Rule 130, Sec. 9), the Deed’s clear and unqualified terms control. It conveyed the parcels absolutely for ₱300,000, free of any reservation of Teodora’s share. No intrinsic ambiguity justified extrinsic evidence of a contrary intent. Petitioners, as abso
Case Syllabus (G.R. No. 244542)
Antecedents
- Federico J. Alferez died intestate on September 23, 1980, survived by spouse Teodora and children Ma. Concepcion, Antonio, and Esperanza.
- Ma. Concepcion filed a Petition for Issuance of Letters of Administration on October 25, 1980 (Special Proceedings No. 437, CFI Branch 5, Davao del Sur).
- The intestate estate comprised one-half of the conjugal partnership properties in Digos City (five parcels covered by OCT Nos. P-6029-1518, P-6028, P-5586; TCT Nos. T-173-29, T-5907).
- Letters of Administration were issued in favor of Ma. Concepcion on January 16, 1981.
- On January 15, 1982, Teodora and petitioners executed an Extrajudicial Settlement with Donation, allocating Teodora’s conjugal halves to Ma. Concepcion, Antonio, and Esperanza respectively.
Sale Authorization and Deed of Sale
- To settle bank debts, Ma. Concepcion filed an Urgent Motion on April 24, 1985, to allow the sale of adjudicated properties.
- Esperanza (1984) and Antonio (March 28, 1985) executed Special Powers of Attorney authorizing Ma. Concepcion to negotiate and sell their respective parcels.
- CFI Order dated August 29, 1985 authorized Ma. Concepcion to sell three parcels adjudicated to each of the petitioners.
- A Deed of Sale with Assumption of Mortgage was executed on October 8, 1985, between petitioners (through their administratrix) and respondents (Spouses Canencia, Norma and Teresa Alforque) for ₱300,000.
Petitioners’ Claim
- Petitioners filed an action for annulment or nullity of the Deed, recovery of possession, damages, and attorney’s fees.
- They alleged the parties intended only to sell Federico’s one-half share, not the entire estate (including Teodora’s conjugal share).
- Ma. Concepcion protested inclusion of the entire p