Case Summary (G.R. No. L-32328)
Background of Legal Proceedings
On November 4, 1963, the intestate proceedings for Adriana Maloto's estate were initiated, wherein her niece and nephews believed that she had died intestate. This led to an extrajudicial partition executed on February 1, 1964, wherein her estate was divided among the said heirs equally. The partition was approved by the Court of First Instance of Iloilo on March 21, 1964. However, complications arose when, on April 1, 1967, a document purporting to be Adriana's last will was presented for probate, indicating potentially different shares for certain heirs.
Motions for Reconsideration and Opposition
Following the discovery of the will, Aldina Maloto Casiano and Constancio Maloto filed motions in the intestate proceeding for reconsideration and for the probate of the will. They were joined by other interested parties, including the Asilo de Molo and the Roman Catholic Church of Molo, in seeking probate. However, Panfilo and Felino Maloto opposed these motions, asserting that the alleged will had been revoked and that the petition was barred by res judicata, as the estate had already been partitioned.
Dismissal of Probation Petition
In an order dated April 13, 1970, the probate court dismissed the petition to probate Adriana Maloto’s will, citing that the will had been previously revoked and that the petition was barred due to the prior ruling in the intestate proceedings. The court's determination was based on earlier findings that disallowed reopening those proceedings. Consequently, the petitioners appealed this dismissal.
Review of Legal Errors
The petitioners highlighted several alleged errors by the lower court, focusing on the mistaken belief that the will had been revoked and that the matter was res judicata. The court also faced criticism for dismissing the petition without appropriately allowing a thorough probate process, which included considering the alleged will's authenticity and validity.
Court's Ruling and Directives
Ultimately, the appellate court found merit in the petitioners' arguments. It held that the probate court lacked the jurisdiction to address the will’s status within the context of the intestate proceedings. It established that find
...continue readingCase Syllabus (G.R. No. L-32328)
Background of the Case
- Adriana Maloto passed away on October 20, 1963, in Iloilo City, leaving behind a question of whether she died intestate or left a will.
- Following her death, her niece and nephews, namely Aldina Maloto Casiano, Constancio Maloto, Panfilo Maloto, and Felino Maloto, initiated intestate proceedings on November 4, 1963, in the Court of First Instance of Iloilo, under Special Proceeding No. 1736.
- An extrajudicial partition was executed by the aforementioned heirs on February 1, 1964, whereby they divided the estate equally among themselves, each receiving one-fourth (1/4) share.
- The Court of First Instance, presided by Judge Emigdio V. Nietes, approved this partition on March 21, 1964.
The Discovery of the Will
- On April 1, 1967, a document dated January 3, 1940, claiming to be Adriana Maloto's last will and testament, was submitted to the Clerk of Court.
- Notably, Aldina Maloto Casiano and Constancio Maloto were named in the will, but their shares were reportedly larger and more valuable than those allocated in the extrajudicial partition.
- The will included provisions for additional devisees and/or legatees, including Asilo de Molo, the Roman Catholic Church of Molo, and Purificacion Miraflor.
Motion for Reconsideration
- On May 24, 1967, Aldina Maloto Casiano and Constancio Maloto filed a motion in Special Proceeding No. 1736 seeking reconsideration, annulment of previous proceedings, and allowance for the will.
- Asilo de Molo, the Roman Catholic Church of Molo, and Purificacion Miraflor also sought the probate of the will.
- Panfilo Maloto and Felino Maloto opposed this motion.
Court Proceedings and Denial of Motion
- The Co