Case Summary (G.R. No. 170243)
Applicable Law
The case is governed by the 1987 Philippine Constitution and relevant provisions of the Rules of Court, particularly concerning appeals in special proceedings.
Background of the Case
Enrique Hinlo died intestate, triggering the need for the administration of his estate. Following his death, his widow Ceferina was appointed as a special administratrix due to her relationship to the deceased. However, due to health issues, she was later replaced by petitioners Nancy H. Zayco and Remo Hinlo. The respondent, Atty. Jesus V. Hinlo, Jr. filed a petition seeking to be appointed as administrator while also moving for the removal of the petitioners. The RTC revoked the petitioners' appointment and granted the respondent letters of administration based upon a P50,000 bond.
Procedural Developments
Petitioners were informed of the RTC's decision on August 2, 2002. They filed a motion for reconsideration shortly after, which was denied on July 23, 2003. Following their receipt of the denial, they filed a notice of appeal on July 31, 2003, and a record on appeal by August 29, 2003. The RTC later ruled that the orders regarding the appointment of the administrator were interlocutory and hence not appealable, also determining that the appeals were tardy.
Court of Appeals Ruling
The petitioners challenged the RTC's ruling by filing a petition for certiorari and mandamus in the Court of Appeals (CA). The CA dismissed the petition on June 27, 2005, asserting that the RTC did not exhibit grave abuse of discretion as the notice of appeal and record were filed beyond the permissible timeframe.
Supreme Court Findings
Upon review, the Supreme Court held that the RTC made an error in classifying the orders as non-appealable. It determined that an order appointing an administrator constitutes a final decision impacting the rights of the parties involved in the estate’s administration. Thus, such an order is indeed appealable. The Court referenced the Neypes doctri
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Case Overview
- This case involves a petition for review filed by Nancy H. Zayco and Remo Hinlo as judicial co-administrators of the estate of Enrique Hinlo against Atty. Jesus V. Hinlo, Jr.
- The case originated from the Court of Appeals' decisions dated June 27, 2005, and October 27, 2005, in CA-G.R. SP No. 82129.
- The primary legal issue revolves around the appealability of certain orders issued by the Regional Trial Court (RTC) regarding the administration of Enrique Hinlo's estate.
Background Facts
- Enrique Hinlo died intestate on January 31, 1986, prompting his heirs to file for letters of administration of his estate in the RTC of Negros Occidental, Silay City, Branch 40.
- Ceferina Hinlo, the widow of Enrique, was appointed as the special administratrix but was later deemed unable to fulfill her duties due to illness.
- On December 23, 1991, Nancy H. Zayco and Remo Hinlo were appointed co-administrators of Enrique's estate.
- On March 4, 2003, Atty. Jesus V. Hinlo, Jr. filed a petition to issue letters of administration in his favor and sought the removal of the petitioners as co-administrators.
RTC Proceedings
- The RTC revoked the petitioners' appointment as co-administrators in an order dated July 23, 2002, and appointed Atty. Jesus V. Hinlo, Jr. as the new administrator.
- Petitioners received the order on August 2, 2002, and