Case Summary (G.R. No. L-18148)

Jurisdiction of Probate Courts in Property Title Disputes

• Generally, questions of title to property cannot be resolved in testate or intestate proceedings, except when a party requests the inclusion or exclusion of property from the inventory.
• In cases where all parties are heirs of the deceased, they may submit questions regarding property title to the probate court, which can then make a definitive ruling.
• The jurisdiction of probate courts extends to controversies between heirs regarding ownership of properties belonging to the deceased's estate.

Liquidation of Conjugal Properties

• Probate courts have the authority to determine whether properties in a testate proceeding belong to a conjugal partnership or to an individual spouse.
• This determination is essential for the liquidation of the estate, as it affects the distribution of assets among heirs.
• The liquidation process involves identifying all assets and settling debts before distributing the remaining estate to heirs and legatees.

Waiver of Objections in Partition Proceedings

• A party that raises an objection regarding property ownership cannot later withdraw that issue from the court's jurisdiction if they initiated the proceedings.
• By presenting a project of partition that includes disputed properties, the party effectively submits the ownership question to the court.
• The court's decision on the matter, after due hearing, is binding on the parties who raised the objection.

Estoppel and Knowledge of Facts

• For estoppel to apply, the party must have knowledge of the relevant facts and their rights at the time of the act that constitutes estoppel.
• Silence or inaction without knowledge does not create estoppel.
• In this case, the deceased widow's actions were based on an illegal deed of donation, which she did not know was void, thus negating any claim of estoppel against her heirs.

Affirmation of the Co...continue reading

Case Syllabus (G.R. No. L-18148)

Background of the Case

• This case arises from a petition for certiorari seeking a review of the decision made by the Court of Appeals, which upheld an earlier ruling by the Court of First Instance of Bulacan.
• The central issue involves the jurisdiction of the probate court to determine the validity of a deed of donation and the title or ownership of properties included therein.

Facts of the Case

• Eusebio Capili and Hermogena Reyes were married; Eusebio passed away on July 27, 1958.
• A testate proceeding for Eusebio's estate was initiated, with his will admitted to probate on October 9, 1958, distributing his properties to various heirs, including Hermogena.
• Hermogena Reyes died on April 24, 1959, leading to her collateral relatives being substituted as parties in the probate proceedings.
• An executor, Deogracias Bernardo, filed a project partition to allocate Eusebio's estate among the testamentary heirs, excluding Hermogena’s share, which was allotted to her collateral relatives.
• The collateral relatives opposed the executor's partition, claiming half of the properties, arguing that they belonged to the conjugal partnership of Eusebio and Hermogena.

Proceedings in the Probate Court

• The probate court held hearings on the competing partition projects, during which evidence was presented and legal memoranda submitted.
• The executor’s memorandum claimed that the propert...continue reading