Case Summary (G.R. No. 1352)
Property Administration and Lease Agreements
Following the death of Florencio Reyes, Sr. on June 23, 1967, the intestate court (now RTC of Pasig City, Branch 151) appointed Oliva R. Arevalo as special and then regular administratrix of the estate. She was later replaced by Florencio Jr., and subsequently Teresa became administratrix in 1994. Teresa executed several lease contracts over the Baguio properties, including leases on the Magsaysay Avenue, Session Road, Loakan, and Military Cut-off properties to various lessees between 1994 and 1997. These leases were approved by the intestate court.
Initiation of Partition and Accounting Proceedings
In 2001, respondents and other heirs filed three complaints with the RTC of Baguio City, Branch 3, seeking judicial partition, the annulment of the lease contracts entered into by Teresa, an accounting of rental payments, and damages. They alleged that the estate was not the sole owner of the disputed properties, contrary to Teresa’s representations, asserting that each heir owned one-tenth of the properties. They also contended that they had not received their rightful shares of the rental income due to Teresa’s failure to account properly.
Judicial Accounting and Procedural Developments
The Baguio RTC commissioned an audit, which found that Teresa was accountable for over P15 million as administratrix. Despite this, the Baguio RTC deferred the case to await instructions from the intestate court regarding the distribution and partition. Respondents moved the intestate court for an order allowing distribution of the heirs’ shares and partition of the properties. However, the intestate court denied the motion, asserting its exclusive jurisdiction over the estate’s matters and refusing to allow a partition in another tribunal.
Court of Appeals Decision
Respondents petitioned the Court of Appeals (CA), which annulled the intestate court’s orders denying the partition and directed the RTC of Baguio City to proceed with partitioning the Baguio properties among the registered co-owners. The CA's ruling emphasized that properties allegedly co-owned by the estate and the heirs should be subject to partition by the court competent to decide property ownership and partition, not exclusively by the intestate court.
Issues Raised in the Petition for Review
Teresa filed a petition before the Supreme Court challenging the CA's decision, arguing: (1) the existence of an adequate remedy by appeal or ordinary course; (2) that respondents effectively urged the trial court to violate procedural rules; and (3) the orders were not issued with grave abuse of discretion. Teresa also asserted that full payment of debts and obligations as per Section 1, Rule 90 of the Rules of Court had not been made, making distribution premature without posting a bond.
Supreme Court’s Analysis on Jurisdiction and Remedies
The Supreme Court clarified that a petition for certiorari under Rule 65 of the Rules of Court is proper only if there is grave abuse of discretion amounting to lack or excess of jurisdiction. The Court noted that the intestate court’s denial of the motion to allow distribution was interlocutory, not final, because it did not conclusively determine ownership or co-ownership of the properties. The intestate court’s jurisdiction is special and limited to probate and settlement of the estate, but does not extend to final determination of property ownership when third-party claims or co-ownerships exist.
Limited Jurisdiction of Intestate Court and Ownership Controversies
The Court reiterated the principle that probate or intestate courts cannot conclusively adjudicate ownership disputes over estate properties; such issues are extraneous to probate and must be resolved through ordinary civil actions. The intestate court may provisionally determine inclusion or exclusion of properties in the estate inventory but cannot replace an ordinary action for final ownership determination. Exceptions apply only when all parties are heirs or consent and when third-party rights are not impaired.
Authority of the Proper Courts to Resolve Partition and Ownership
The Court explained that an action for partition under Rule 69 of the Rules of Court requires a clear determination of co-ownership as a prerequisite to judicial partition. It held that the RTC of Baguio City had the ju
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Case Syllabus (G.R. No. 1352)
Facts of the Case
- Florencio Reyes, Sr. died intestate on June 23, 1967, leaving several heirs including Teresa R. Ignacio and respondents Ramon Reyes, Florencio Reyes, Jr., Rosario R. Du, and Carmelita R. Pastor.
- On July 11, 1967, Angel Reyes and Oliva R. Arevalo filed a petition for Letters of Administration over the estate of Florencio Sr. before the then Court of First Instance of Rizal (now RTC of Pasig City, Branch 151).
- Oliva was appointed as special administratrix initially and then as regular administratrix; in 1982, Florencio Jr. replaced her, and eventually Teresa Ignacio became administratrix in 1994.
- Teresa, as administratrix, entered into lease contracts over several parcels of land located in Baguio City, including:
- A 398 sq. m. land on Magsaysay Avenue (TCT No. T-59201).
- A 646 sq. m. land on Session Road (TCT No. T-26769).
- Other lands on Loakan Road (TCT Nos. T-26770 and T-26772) leased to various lessees for ten-year periods starting in 1996.
- The intestate court approved the lease contracts in 1996.
- In 2001, respondents and other heirs filed complaints before the RTC of Baguio City for partition, annulment of lease contracts, accounting, damages, and preliminary injunctions against Teresa and her lessees.
- The plaintiffs alleged that the properties were co-owned by all heirs in equal shares (1/10 each), that Teresa had misrepresented estate ownership, and failed to account for rentals.
- The Baguio RTC commissioned an accounting audit which revealed cash accountability by Teresa amounting to PHP 15,238,066.51.
- Respondents moved for distribution of heirs’ shares and property partition before the intestate court, which denied the motion in 2004 and upheld denial upon reconsideration in 2012.
- Respondents petitioned the Court of Appeals, which annulled and set aside the intestate court’s orders denying the partition, directing the Baguio RTC to proceed with partition.
- Teresa elevated the case to the Supreme Court questioning the CA decision and the jurisdictional aspects of the intestate court and the proper remedy.
Issues Presented
- Whether there was an available plain, speedy, and adequate remedy in the ordinary course of law other than the petition for certiorari.
- Whether the intestate court abused its discretion in denying the motion for partition and distribution of shares in favor of the heirs and co-owners.
- Whether the assailed orders denying the distribution and partition by the intestate court were final and appealable or interlocutory in nature.
- Whether the intestate court has jurisdiction to finally determine ownership and co-ownership of the subject properties registered in the names of respondents and the estate.
Jurisdictional and Procedural Background
- The intestate court (RTC, Pasig City, Branch 151) exercises special and limited jurisdiction over the probate of wills and settlement of the deceased’s estate.
- Ownership questions concerning estate properties, especially those involving registered titles claimed by parties outside the estate, fall outside the intestate court’s definitive jurisdiction.
- The Baguio RTC, Branch 3, has pe
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