Title
Batugan vs. Balindong
Case
G.R. No. 181384
Decision Date
Mar 13, 2009
Dispute over partition of expropriated Coloi Farmland proceeds among heirs; Shari'a Court's final orders upheld, excluding further claims.

Case Summary (A.C. No. 10532)

Proceedings and Initial Orders

During his lifetime, Hadji contracted two marriages and left behind several properties upon his death on September 6, 1990. Notably, part of his estate included the Coloi Farmland, which had been subject to expropriation proceedings initiated by the National Power Corporation (NPC) for just compensation. On July 29, 1991, the trial court ruled that Hadji was entitled to compensation of Php766,580.00 from NPC, which eventually led to disputes among the heirs regarding the distribution of this amount.

Shari'a Court's Approval of Partition

Petitioner filed a special civil action for partition in May 1999, resulting in Civil Case No. 02-99. On July 2, 2003, the Shari'a Court recognized the petition and approved a partition based on applicable laws under Presidential Decree No. 1083. Multiple project plans for the partition were submitted, leading up to the May 6, 2005 Order that established the sharing of the properties among the heirs, including the Coloi Farmland.

Issuance of Writ of Execution and Subsequent Motions

Following the Shari’a Court's orders, and upon failing to finalize the partition due to disputes over the project plans, multiple motions were filed, including a motion for amendment to the writ issued on March 7, 2007. The Shari'a Court granted some motions but ultimately recognized an extra-judicial partition of the Coloi Farmland among the heirs in its June 18, 2007 Order, directing that the case concerning it be closed.

Petitioner’s Contentions and Court's Findings

Petitioner contended that the Shari'a Court abused its discretion in choosing to recognize the extra-judicial partition, which he argued had not been finalized within the court. Petitioner argued that the writ of execution issued on March 7, 2007 had not been quashed and thus should be enforced. However, the Supreme Court found that the Court had acted within its discretion.

Jurisdictional and Procedural Issues

The petition faced a crucial procedural hurdle. Petitioner failed to comply with the requirements for filing a certiorari petition, including not providing the necessary material dates and specific documents. This procedural deficiency warranted dismissal, irrespective of the case's substantive merits. The Supreme Court maintained that procedural rules are strictly en

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