Case Summary (G.R. No. 179859)
Content and Legal Character of the Will
The will appointed Ma. Pilar as manager/administrator of specified properties and directed that certain properties be transferred to the names of Ma. Pilar and Clemente not as their inheritance but for administration and safekeeping, with a stated purpose that members of the testator’s family could use the Manila house if they needed lodging for study. The will made several dispositive provisions: (1) some properties (rice mill, machinery, animal feed factory, and various lands) were bequeathed to the testator’s spouse (Cecilia) and named children equally, but prohibited partition of those properties for twenty (20) years from the testator’s death; (2) during that 20‑year period the properties were to be managed by Ma. Pilar and Clemente, with Ma. Pilar handling the funds and distributions of net income after necessary expenses; and (3) certain lands (including the Manila house and lot) were to be put in the names of Ma. Pilar and Clemente for administration only, and the will expressed that the property was not to be owned by any one person but to be used in common by the testator’s descendants.
Probate, Final Accounting and Initial Registration of Titles
Petitioner Ma. Pilar filed for probate of the will and was appointed executrix. The probate court admitted the will and later approved a “Final Accounting, Partition and Distribution in Accordance with the Will” by Order dated August 14, 1978. The Court directed registration of titles as indicated in the will, and Transfer Certificates of Title for several lots in Malolos, Bulacan (Lot Nos. 786, 837, 7922, 836, and 838) and Lot No. 8‑C in Manila were issued in the names of Ma. Pilar and Clemente.
Complaint‑in‑Intervention and Civil Case for Completion of Legitime
Oppositors (children of the decedent’s first marriage) intervened and then filed a Complaint‑in‑Intervention in the probate proceedings, alleging among other things that the decedent’s second wife was not the person identified in the will and that the will violated the Civil Code provisions on succession (Arts. 979–981 regarding legitimate children and their shares). The probate court dismissed the Complaint‑in‑Intervention (citing its earlier approval of the Final Accounting). The oppositors then filed a separate civil action (Civil Case No. 562‑M‑90) for the completion of legitime, asserting partial preterition and reduction of their legitime and seeking inventory, appraisal, and accounting of all properties from the decedent’s death to the filing of that civil case.
Appellate Proceedings on Legitime and Res Judicata Ruling
The RTC’s decision in the completion‑of‑legitime case was appealed. The Court of Appeals, in CA G.R. No. 45801 (Decision of January 25, 2002), annulled the RTC decision on the ground of res judicata, holding that the probate court’s August 14, 1978 Order approving the will and Final Accounting constituted a res judicata bar to the oppositors’ claims in Civil Case No. 562‑M‑90 and directed that the decree of distribution remain undisturbed. The oppositors sought review to the Supreme Court (G.R. No. 155606) but the petition was denied and the denial became final and executory on April 9, 2003.
Motion for Termination of Administration, RTC Order of September 5, 2003
Separately, on October 17, 2000, heirs of the second marriage filed before the probate court a Motion for Termination of Administration, for Accounting, and for Transfer of Titles in the Names of the Legatees. They alleged that the 20‑year prohibition against partition expired on September 16, 1993 and that Ma. Pilar and Clemente should therefore have ceased to act as administrators, transferred titles to the named legatees, and rendered a full accounting from the decedent’s death to the present. The probate court granted the motion by Order dated September 5, 2003, directing surrender of the registered titles to the court, transfer of titles in the names of the legatees designated in the will (Cecilia and the children named), peaceful surrender of possession and administration, full accounting from August 14, 1978 to present, and submission of a proposed project of partition. The court also ordered the Registers of Deeds in Bulacan and Manila to cancel the existing TCTs in the names of Ma. Pilar and Clemente and to issue new titles in the names of the legatees.
Rationale of the Probate Court on Continuing Administration and Accrual of Rights
The probate court explained that the August 14, 1978 Order only approved accounting, partition and distribution for the period up to that date and did not terminate the appointment of Ma. Pilar and Clemente as executrix/administrator for those properties expressly prohibited from partition for 20 years. The court treated the probate administration as continuing in character and held that the cause of action to demand termination, accounting and transfer accrued only after the lapse of the 20‑year prohibition (i.e., after September 16, 1993). For that reason the principle of res judicata did not apply to bar the later motion and proceedings relating to final settlement after the prohibition period lapsed.
Court of Appeals Affirmation and Issues Raised to the Supreme Court
On appeal from the probate court’s September 5, 2003 Order, the Court of Appeals (CA G.R. No. 83094) affirmed the probate court’s ruling. Petitioners sought review before the Supreme Court raising principally: (1) whether the Court of Appeals erred in not being bound by its earlier decision in CA G.R. No. 45801 (and hence reversing itself on res judicata), and (2) whether the inclusion of the Manila house and lot (TCT No. 131044) among properties to be transferred to the legatees contravened the testator’s expressed intent that no one own that property (i.e., that it be used without ownership).
Supreme Court Analysis on Res Judicata and Identity of Cause of Action
The Supreme Court analyzed res judicata under Sections 47(b) and 47(c) of Rule 39, distinguishing the two aspects: (a) “bar by prior judgment” (same claim/demand/cause of action) and (b) “conclusiveness of judgment” (issues actually and directly resolved in a former suit). The Court found that neither aspect applied to bar the present proceedings. The earlier final judgment (G.R. No. 155606 / CA G.R. No. 45801) concerned the oppositors’ complaint on the reduction of their legitime; it did not address nor resolve the separate question of termination of administration, accounting after the 20‑y
...continue readingCase Syllabus (G.R. No. 179859)
Parties and Family Relationships
- Decedent: Basilio Santiago, who contracted three marriages:
- First marriage to Bibiana Lopez, issue: Irene and Marta. Marta is the mother of oppositors Filemon (Filemon) Soco, Leonila Soco, Consolacion (deceased, heirs), Ananias Soco, Urbano Soco, and Gertrudes Soco (all surnamed Soco).
- Second marriage to Irene Santiago (disputed later), issue: Tomas, Cipriano, Ricardo, Zoilo (respondent), Felicidad (respondent, Felicidad Santiago-Rivera), and Ma. Pilar (petitioner), all surnamed Santiago.
- Third marriage to Cecilia Lomotan, issue: Eugenia, Clemente (petitioner), and Cleotilde, all surnamed Santiago.
- Petitioners: Ma. Pilar Santiago and Clemente Santiago (legatees named in the will; Ma. Pilar later executrix/administratrix).
- Respondents: Zoilo S. Santiago, Felicidad Santiago-Rivera, heirs of Ricardo, Cipriano, Tomas (heirs of the second marriage).
- Oppositors: Filemon (Filemon) Soco, Leonila Soco, Ananias Soco, Urbano Soco, Gertrudes Soco, and heirs of Consolacion Soco (children of Marta, daughter of Basilio and first wife Bibiana Lopez).
Facts: Death, Probate Petition, and Initial Probate Proceedings
- Basilio Santiago died testate on September 16, 1973.
- Petitioner Ma. Pilar filed a petition for probate of Basilio’s Last Will and Testament before the Regional Trial Court (then Court of First Instance) of Bulacan, docketed SP No. 1549-M.
- Branch 10 of the RTC admitted the will to probate and appointed Ma. Pilar as executrix.
- Petitioner-executrix filed a “Final Accounting, Partition and Distribution in Accordance with the Will.”
- The probate court approved the will by Order dated August 14, 1978 and directed the registers of deeds of Bulacan and Manila to register the certificates of title indicated in the will.
- Consequently, Transfer Certificates of Title for Lot Nos. 786, 837, 7922, 836 and 838 in Malolos, Bulacan and Lot No. 8‑C in Manila were transferred in the names of Ma. Pilar and Clemente.
Relevant Provisions of the Will (Clauses c–g as presented)
- Clause c: Ma. Pilar is to manage and supervise the “balutan” in Santiago, Malolos, Bulacan (described as 2(y) in the will).
- Clause d: Conveys that under management of the rice mill (bigasan), animal feeds factory (pagawaan ng pagkain ng hayop), and the house and lot in Manila, all solares along the Malolos-Paombong road in Malolos, Bulacan, including the fishpond behind them, shall be transferred in the names of Ma. Pilar and Clemente; income from the fishpond to be used for necessary expenses, major repairs or operations on the house and lot in the City of Manila (referred to as 2(c) in the will).
- Clause e: The house and lot in the City of Manila (2(c)) shall be transferred and placed in the names of Ma. Pilar and Clemente not as inheritance but to be administered and cared for by them so that any of Basilio’s children, grandchildren and great‑grandchildren may have lodging while studying in Manila or nearby cities; that is, the house and lot are not to be owned by any one person but used by any of the descendants who wish to study in Manila and adjacent cities.
- Clause f: The rice mill, machines and animal feeds factory are bequeathed to Basilio’s wife Cecilia Lomotan and his children Tomas, Zoilo, Ma. Pilar, Ricardo, Cipriano, Felicidad, Eugenia, Clemente and Cleotilde, equally, but they are not to partition these properties within twenty (20) years from Basilio’s death; management during the 20-year period is vested in Clemente, and Ma. Pilar is to handle the funds and distribution; only income after necessary expenses may be distributed.
- Clause g: All lands, except the house and lot in Manila (2(c)), are bequeathed to Cecilia Lomotan and the listed children equally; similarly, these properties are not to be partitioned for 20 years from death and are to be managed by Ma. Pilar and Clemente; only income or harvest after taxes and necessary expenses may be distributed, with Ma. Pilar keeping the produce or proceeds.
Intervention by Oppositors and Complaint-in-Intervention
- On motion, the oppositors (children of Marta from the first marriage) were allowed to intervene in the probate proceeding.
- The oppositors filed a Complaint-in-Intervention asserting, inter alia:
- Basilio’s second wife was not Irene but a certain Maria Arellano with whom he had no child (challenging pedigree and status).
- The will violated Articles 979–981 of the Civil Code (succession rules concerning legitimate children and representation).
- The probate court dismissed the Complaint-in-Intervention, referencing its prior approval of the Final Accounting, Partition, and Distribution in Accordance with the Will (August 14, 1978 Order).
Civil Case No. 562‑M‑90: Completion of Legitime and Procedural History
- The oppositors (heirs of the first marriage) filed a separate complaint for completion of legitime before the Bulacan RTC, docketed Civil Case No. 562‑M‑90, against the heirs of the second and third marriages.
- In Civil Case No. 562‑M‑90, oppositors alleged partial preterition by Basilio’s will because their legitime was reduced; they prayed for an inventory and appraisal of Basilio’s properties and for Ma. Pilar and Clemente to submit a fresh accounting of incomes from the time of Basilio’s death to the filing of Civil Case No. 562‑M‑90.
- RTC-Branch 17 rendered judgment in favor of the oppositors in Civil Case No. 562‑M‑90.
Court of Appeals Decision in CA G.R. No. 45801 and Subsequent Supreme Court Action
- On appeal from RTC-Branch 17 (Civil Case No. 562‑M‑90), the Court of Appeals (CA), in CA G.R. No. 45801, by Decision of January 25, 2002, annulled the RTC decision and held that the dismissal of the Complaint-in-Intervention in SP No. 1549-M and the August 14, 1978 Order approving the probate of the will constituted res judicata with respect to Civil Case No. 562‑M‑90.
- The CA disposed: Appeal GRANTED; Decision in Civil Case No. 562‑M‑90 ANNULLED on the ground of res judicata; Decree of Distribution of the Estate of Basilio Santiago REMAIN UNDISTURBED.
- The oppositors petitioned this Court in G.R. No. 155606; this Court denied the petition and that denial became final and executory on April 9, 2003.
Motion for Termination of Administration, for Accounting, and for Transfer of Titles (Oct 17, 2000)
- On October 17, 2000, the heirs of the second marriage filed before the probate court (RTC‑Branch 10) a Motion for Termination of Administration, for Accounting, and for Transfer of Titles in the Names of the Legatees.
- Respondents’ primary contentions in the motion:
- The twenty (20) year prohibition period within which the subject properties were to be under administration by Ma. Pilar and Clemente expired on September 16, 1993.
- Consequently, Ma. Pilar and Clemente should have ceased administration as of September 16, 1993 and should have transferred the titles to the legatees named in the Last Will and Testament.
- Ma. Pilar and Clemente should have rendered an accounting of their administration from the time of Basilio’s death up to the present.
- Reliefs prayed for by respondents included:
- To surrender and transfer the enumerated titles presently in petitioners’ names to the designated legatees (listed: Cecilia Lomotan and children Tomas, Zoilo, Ma. Pilar, Ricardo, Cipriano, Felicidad, Eugenia, Clemente, Cleotilde).
- Peaceful surrender of possession and administration of the properties to the legatees.
- Rendering an accounting of administration from Basilio’s death (Sept 16, 1973) up to the present and until transfer.