Case Summary (G.R. No. 179859)
Probate Proceedings and Intervention
RTC Branch 10 admitted the will to probate in 1978, appointing Ma. Pilar as executrix. Oppositors (Soco siblings) intervened, later alleging the will violated legitime rules (Civil Code Articles 979–981). The probate court dismissed their intervention, finalizing the decree of distribution and prompting the Soco heirs to file a separate legitime completion suit (Civil Case No. 562-M-90).
Res Judicata on Legitime Claim
The Court of Appeals (CA G.R. No. 45801) held the probate court’s 1978 approval barred the Soco heirs from contesting legitime under res judicata. The Supreme Court denied review (G.R. No. 155606), making that ruling final as to the first marriage heirs’ legitime challenge.
Motion for Termination of Administration
Heirs of the second marriage filed in 2000 a motion in the continuing probate (SP No. 1549-M) to terminate administration, render a full accounting since Basilio’s death, and transfer titles to all legatees—contending the twenty-year prohibition expired in 1993.
Probate Court Order of 2003
The probate court granted the motion, directing Ma. Pilar and Clemente to surrender titles, transfer them to all legatees (including Cecilia Lomotan and all ten Santiago heirs), render accounting from 1978 onward, and propose a partition scheme. It rejected res judicata, noting probate is continuous until final distribution.
Appeals and Conflicting Appellate Rulings
The Soco heirs and petitioners moved for reconsideration. The Court of Appeals (CV G.R. No. 83094) affirmed the probate court’s order, rejecting res judicata and upholding the need to conclude administration and transfer titles after the twenty-year indivision.
Supreme Court Review and Res Judicata Analysis
The petitioners argued the earlier CA decision (CA G.R. No. 45801) barred further proceedings. The Supreme Court clarified res judicata’s two aspects—bar by prior judgment and conclusiveness of judgment—do not apply here because the 1978 decree did not address termination of administration, accounting, or title transfer post-prohibition period. The issues and causes of action differ, and the probate proceeding remained open.
Interpretation of Indivision Period and Property Transfer
The Court affirmed that the twenty-year prohibition on partition
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Facts of the Case
- Decedent Basilio Santiago entered into three marriages and had children by each:
• First marriage to Bibiana Lopez produced Irene and Marta (mother of the Soco oppositors)
• Second marriage to Irene Santiago produced Tomas, Cipriano, Ricardo, Zoilo, Felicidad, and Ma. Pilar (petitioners and respondents)
• Third marriage to Cecilia Lomotan produced Eugenia, Clemente (petitioner), and Cleotilde - Basilio died testate on September 16, 1973; his will was offered for probate by daughter Ma. Pilar before the RTC of Bulacan
- Branch 10 of the RTC admitted the will to probate, appointed Ma. Pilar executrix, and approved a “Final Accounting, Partition and Distribution in Accordance with the Will” on August 14, 1978
- Certificates of title for various Bulacan and Manila properties were transferred in the names of Ma. Pilar and Clemente
Will Provisions Governing Administration and Distribution
- Clause 4(c): Ma. Pilar to manage the “balutan” in Santiago, Malolos, Bulacan
- Clause 4(d): All Malolos–Paombong road solar lots and fisheries to be transferred to Ma. Pilar and Clemente; fishery income to fund Manila properties
- Clause 4(e): Manila house and lot to be held in trust by Ma. Pilar and Clemente for the use of any child, grandchild or great-grandchild wishing to study in Manila or nearby
- Clause 4(f): Rice mill, machinery, and animal feed factory bequeathed equally to Cecilia Lomotan and nine children; prohibition against partition or distribution of income within 20 years; administration by Clemente, with Pilar handling receipts
- Clause 4(g): All remaining lands bequeathed equally to Cecilia and the nine children; same 20-year prohibition; administration by Ma. Pilar and Clemente; only net income divisible
Procedural History
- Oppositors (children of Marta, first marriage) intervened and filed a Complaint-in-Intervention, challenging legitimacy and will’s c