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Macias vs. Uy Kim

The petition was dismissed and the appealed order of the Court of First Instance of Manila, Branch X, was affirmed, the Supreme Court holding that Branch X lacked jurisdiction to entertain a complaint seeking the annulment of orders issued by Branch VIII in a pending special proceeding for the settlement of the estate of Rosina Marguerite Wolfson. The probate court that first took cognizance of estate settlement proceedings exercises jurisdiction to the exclusion of all other courts, and coordinate branches of the same court may not interfere with each other's orders or judgments. The petitioner's claims regarding his hereditary interest and the nullity of the sale of estate properties were matters properly within the probate court's exclusive competence, and identical reliefs were already being sought in pending appeals before the Supreme Court.

Primary Holding

A coordinate branch of a Court of First Instance has no jurisdiction to annul, review, or interfere with orders issued by another branch of the same court in a pending probate proceeding, the probate court first taking cognizance of the estate settlement retaining exclusive jurisdiction over all questions incident thereto, including the validity of wills, declaration of heirs, disposition of estate property, and distribution of the residue.

Background

Manuel Y. Macias claimed to be a beneficiary of the estates of Julian Wolfson and Rosina Marguerite Wolfson, both of which were under settlement in separate special proceedings before different branches of the Court of First Instance of Manila. Special Proceedings No. 57405 involved the estate of Julian, while Special Proceedings No. 63866 involved the testate estate of Rosina. Macias's alleged interest in Julian's estate rested on a memorandum in which Julian expressed a hope that Rosina would, after his estate was settled, give Macias the sum of ₱500.00 — a document that was not a will. Rosina died without acting on the memorandum. Ricardo Vito Cruz had been appointed ancillary administrator of Rosina's estate. Macias had pending appeals before the Supreme Court (G.R. Nos. L-29235, L-28054, L-28947, and L-30935) challenging various orders in the settlement proceedings.

History

  1. CFI Manila, Branch VIII (Special Proceedings No. 63866), Apr. 15 and 16, 1969 — Judge Barcelona ordered cancellation of Macias's notice of lis pendens and authorized the ancillary administrator to sell estate properties for payment of taxes and expenses of administration.

  2. CFI Manila, Branch VIII, Apr. 24, 1969 — Judge Barcelona approved the deed of sale of five lots to Reliable Realty Corporation; new transfer certificates of title were issued in the corporation's name.

  3. CFI Manila, Branch X (Civil Case No. 76412), May 5, 1969 — Macias filed a complaint for annulment of the deed of sale, reivindicacion, and damages against the buyers and the ancillary administrator.

  4. CFI Manila, Branch X, June 30, 1969 — Judge Moya granted the motion to dismiss and dismissed the complaint for lack of jurisdiction, holding that Branch X had no authority to annul Branch VIII's orders and that distribution of the estate belonged exclusively to the probate court.

  5. Supreme Court, Jan. 23, 1970 — Denied respondents' motion to dismiss the petition for review on certiorari.

  6. Supreme Court, May 30, 1972 — Dismissed the petition and affirmed the appealed order, with costs against petitioner-appellant.

Facts

Manuel Y. Macias claimed to be a beneficiary of the estate of Julian Wolfson, then under settlement in Special Proceedings No. 57405 before Branch VI of the Manila Court of First Instance, and of the estate of Rosina Marguerite Wolfson, under settlement in Special Proceedings No. 63866 before Branch VIII of the same court. His interest in Julian's estate derived solely from a memorandum in which Julian expressed the hope that Rosina would, after his estate was settled, give Macias ₱500.00 — a memorandum that was not a will. Rosina died on September 14, 1965 without having acted on it. Macias had not been declared an heir or legatee of either estate. He had, however, appealed to the Supreme Court from several orders in the settlement proceedings, including the order appointing Ricardo Vito Cruz as ancillary administrator (G.R. No. L-29235) and the order dismissing Special Proceedings No. 67302 (G.R. No. L-28054).

To protect his claimed interest, Macias caused a notice of lis pendens to be annotated on Transfer Certificates of Title Nos. 49877, 49878, 49879, 49880, and 49881, all issued in Rosina's name and covering five adjacent lots in Tondo, Manila. On April 16, 1969, Judge Manuel P. Barcelona of Branch VIII, acting in Special Proceedings No. 63866, authorized Vito Cruz as ancillary administrator to sell the estate's real properties for the payment of estate and inheritance taxes, realty taxes, and expenses of administration. Vito Cruz negotiated the sale of the five lots to Reliable Realty Corporation, organized by respondents Uy Kim, Andres Co, Nicasio Co, Nemesio Co, and Manuel Sosantong, which offered ₱400,000.00 on condition that the notice of lis pendens be cancelled. On April 15, 1969, Judge Barcelona ordered the cancellation of the lis pendens; on April 24, 1969, he approved the deed of sale. New transfer certificates of title were thereafter issued in favor of Reliable Realty Corporation.

On May 5, 1969, Macias filed a complaint in Branch X of the Manila Court of First Instance, docketed as Civil Case No. 76412, seeking annulment of the deed of sale, reivindicacion, and damages. He alleged that the orders of April 15 and April 24, 1969 were issued without notice to him and without jurisdiction, as his appeal in G.R. No. L-29235 had divested Branch VIII of jurisdiction. He also caused a notice of adverse claim to be annotated on the new titles issued to Reliable Realty Corporation. The private respondents moved to dismiss on grounds of lack of jurisdiction, failure to state a cause of action, pendency of another action, and lack of legal capacity to sue. Respondent Vito Cruz sought intervention, reiterating the same grounds.

On June 30, 1969, Judge Jose L. Moya of Branch X sustained the motion to dismiss and dismissed the complaint, citing the rule that a coordinate branch may not annul the orders of another branch and that distribution of the estate belongs exclusively to the probate court. The prayer for cancellation of the notice of adverse claim was denied. Macias appealed by filing the present petition for review on certiorari. Meanwhile, Macias had also filed a separate petition for certiorari, prohibition, and mandamus in G.R. No. L-30935 (entitled Macias vs. University of Michigan, et al.), questioning the validity of the same orders of Branch VIII and seeking substantially the same relief.

Arguments of the Petitioners

  • Nature of the Action: Petitioner maintained that his complaint in Civil Case No. 76412 was not for the annulment of any judgment or order of Branch VIII, and that neither the prayer nor the body of the complaint sought such annulment.
  • Jurisdiction Divested by Appeal: Petitioner argued that his appeal in G.R. No. L-29235 had divested the Presiding Judge of Branch VIII of jurisdiction in Special Proceedings No. 63866, rendering the orders of April 15 and April 24, 1969 null and void for having been issued without jurisdiction and without notice to him.
  • Distributive Share: Petitioner insisted that he sought to recover his distributive share of the estate of Rosina, which he claimed the five lots constituted.
  • Applicability of Cited Cases: Petitioner invoked Lajom vs. Viola, Ramirez vs. Gmur, Rodriguez vs. Dela Cruz, and Quion vs. Claridad as authority for filing an independent action by a preterited heir or legatee.

Arguments of the Respondents

  • Lack of Jurisdiction: Respondents argued that Branch X had no jurisdiction over the subject matter, which properly belonged exclusively to Branch VIII and Branch IV before which the special proceedings were pending, and that petitioner's claim of beneficiary interest depended on recognition by the probate court.
  • No Cause of Action: Respondents contended that the complaint stated no cause of action because Branch X, being coordinate with Branch VIII, had no authority to annul the questioned orders, and that petitioner had already appealed the same orders to the Supreme Court in G.R. No. L-30935.
  • Not a Real Party in Interest: Respondents argued that petitioner was not a beneficiary, legatee, creditor, or heir of Rosina, his alleged interest resting solely on Julian's memorandum, which was not a will, and that Rosina died without complying with it; since he had not been declared an heir or legatee in either special proceeding, he lacked legal standing.
  • Corporate Personality: Respondents supplemented their motion to dismiss by alleging that Reliable Realty Corporation had a personality distinct from its incorporators, so no cause of action lay against the individual respondents.

Issues

  • Jurisdiction of Coordinate Branches: Whether a coordinate branch of the Court of First Instance may annul or review orders issued by another branch of the same court in a pending probate proceeding.
  • Exclusive Probate Jurisdiction: Whether questions concerning the settlement and distribution of a decedent's estate, including the validity of a sale of estate properties, must be resolved within the probate proceeding and not in a separate civil action.
  • Real Party in Interest: Whether petitioner had legal standing to file the complaint, given that he had not been declared an heir or beneficiary of either estate.
  • Multiplicity of Suits: Whether the complaint was barred by the pendency of another action involving the same subject matter and seeking substantially the same relief.

Ruling

  • Jurisdiction of Coordinate Branches: No. A coordinate branch of the Court of First Instance has no authority to annul, review, or interfere with the orders or judgments of another coordinate branch, the branch first acquiring jurisdiction retaining it to the exclusion of all others.
  • Exclusive Probate Jurisdiction: Yes. All questions concerning the settlement of the estate — including the validity of the sale of estate properties, declaration of heirs, and distribution of the residue — must be acted upon within the same special proceedings before the probate court, not in a separate civil action.
  • Real Party in Interest: No. Petitioner had not been declared an heir, legatee, or beneficiary of either estate; his claim rested on a memorandum that was not a will, and Rosina died without acting on it.
  • Multiplicity of Suits: Yes. Petitioner's pending petition in G.R. No. L-30935 amply covered the same subject matter and sought substantially the same relief as his complaint in Civil Case No. 76412 and the present petition.

Ruling Rationale

  • Jurisdiction of Coordinate Branches: The orders sought to be annulled were issued by Judge Barcelona of Branch VIII in Special Proceedings No. 63866, while the complaint was filed in Branch X presided over by Judge Moya. Under established jurisprudence, the various branches of a Court of First Instance, having equal authority and exercising concurrent and coordinate jurisdiction, may not interfere with each other's cases, orders, or judgments. This doctrine assures stability and consistency in judicial actuations and avoids confusion that would ensue if coordinate courts were permitted to interfere with each other's lawful orders. Petitioner's denial that he sought annulment of Branch VIII's orders was belied by paragraphs 8 and 9 of his own complaint, which impugned the validity of the orders of April 15 and April 24, 1969, and by his motion of May 5, 1969, in which he expressly stated that he filed the complaint to nullify and set aside certain orders of Judge Barcelona. Even without those paragraphs, his prayer for nullification of the deed of sale could not be decreed without passing upon the validity of Branch VIII's orders authorizing and approving the sale.

  • Exclusive Probate Jurisdiction: Section 1 of Rule 73 of the Rules of Court provides that the court first taking cognizance of the settlement of the estate of the deceased exercises jurisdiction to the exclusion of all other courts. The rationale is that the settlement of an estate constitutes but one proceeding, and for successful administration there must be but one court with exclusive control over every part of it; entrusting it to two or more independent courts would result in confusion and delay. This provision was inserted in the public interest for the better administration of justice, not for the benefit of parties litigant. Any challenge to the validity of a will, objection to authentication, and every demand or claim by an heir, legatee, or party in interest must be acted upon and decided within the same special proceedings. The distribution of the estate is within the exclusive jurisdiction of the probate court. Petitioner's insistence that he sought to recover his distributive share all the more removed the case from Branch X's jurisdiction, as he must seek his remedy in the probate court hearing Special Proceedings No. 63866.

  • Real Party in Interest: Petitioner's alleged interest in the estate of Julian rested solely on a memorandum in which Julian hoped Rosina would give Macias ₱500.00 after his estate was settled. The memorandum was not a will. Rosina died without complying with it. Petitioner had not been declared an heir or legatee of Julian in Special Proceedings No. 57405 or of Rosina in Special Proceedings No. 63866, and thus lacked legal standing. The cases petitioner cited — Lajom vs. Viola, Ramirez vs. Gmur, Rodriguez vs. Dela Cruz, and Quion vs. Claridad — were inapplicable because those actions were filed by preterited heirs or legatees long after the probate or partition proceedings had been closed or terminated, whereas Special Proceedings No. 63866 was still pending.

  • Multiplicity of Suits: Petitioner's pending petition in G.R. No. L-30935 questioned the validity of the same orders of Branch VIII and sought substantially the same relief as his complaint in Civil Case No. 76412 and the present petition. Petitioner himself acknowledged that the decisions in G.R. Nos. L-29235, L-28947, and L-30935 would determine whether he had legal interest in the estates. The Court noted petitioner's proclivity to file several actions covering the same subject matter and seeking substantially identical relief, unduly burdening the courts. Given his ability and long experience at the bar, such conduct was reprehensible and merited rebuke.

Doctrines

  • Exclusive Jurisdiction of the Probate Court — Under Section 1, Rule 73 of the Rules of Court, the court first taking cognizance of the settlement of the estate of the deceased exercises jurisdiction to the exclusion of all other courts. All questions concerning the settlement — including the validity of the will, declaration of heirs, disposition of estate property for payment of liabilities, and distribution of the residue — must be resolved within the same special proceedings, not in a separate civil action. The Court applied this by holding that Branch VIII, where Special Proceedings No. 63866 was pending, had exclusive jurisdiction over all matters incident to Rosina's estate, including the validity of the sale of its properties.

  • Non-Interference Among Coordinate Courts — The various branches of a Court of First Instance, having equal authority and exercising concurrent and coordinate jurisdiction, may not interfere with the cases, orders, or judgments of each other. The branch first acquiring jurisdiction retains it to the exclusion of all other branches. The Court applied this by holding that Branch X could not annul or review the orders issued by Branch VIII, a coordinate branch, in Special Proceedings No. 63866.

  • Proper Remedy for Preterited Heir — The better practice for an heir who has not received his share is to demand it through a proper motion in the same probate or administration proceedings, or for reopening thereof if already closed, rather than through an independent action before another court. The Court noted that even in Quion vs. Claridad, invoked by petitioner, the intestate proceedings, though closed and terminated, could still be reopened within the prescriptive period upon petition by a preterited heir — but here the proceedings were still pending.

Key Excerpts

  • "The various branches of a Court of First Instance of a province or city, having as they have the same or equal authority and exercising as they do concurrent and coordinate jurisdiction, should not, cannot, and are not permitted to interfere with the respective cases, much less with their orders or judgments, by means of injunction." — This passage, quoting De Leon vs. Salvador, articulates the canonical formulation of the doctrine prohibiting coordinate courts from interfering with each other's orders, the controlling rationale for the dismissal.

  • "The reason for this provision of the law is obvious. The settlement of the estate of a deceased person in court constitutes but one proceeding. For the successful administration of that estate it is necessary that there should be but one responsible entity, one court, which should have exclusive control of every part of such administration. To intrust it to two or more courts, each independent of the other, would result in confusion and delay." — This passage states the rationale for Section 1, Rule 73, explaining why exclusive probate jurisdiction is required in the public interest.

  • "The provision of section 602, giving one court exclusive jurisdiction of the settlement of the estate of a deceased person, was not inserted in the law for the benefit of the parties litigant, but in the public interest for the better administration of justice. For that reason the parties have no control over it." — This passage emphasizes that the rule on exclusive probate jurisdiction is a matter of public policy, not party convenience, reinforcing its mandatory character.

Precedents Cited

  • Tuason vs. Judge Torres, 21 SCRA 1169 (1967) — Cited by the lower court for the proposition that jurisdiction to annul a judgment or order of a branch of the CFI is vested exclusively in the branch that rendered it, and any other coordinate branch that attempts to do so exceeds its jurisdiction. Followed.
  • De Leon vs. Salvador, 36 SCRA 567 (1970) — Cited for the doctrine that coordinate branches of a CFI may not interfere with each other's cases, orders, or judgments. Followed as controlling.
  • Pagkalinawan vs. Gomez, 21 SCRA 1275 (1967) — Cited for the principle that permitting coordinate courts to interfere with each other's lawful orders would be subversive of a steadfastly adhered-to doctrine and fraught with undesirable consequences. Followed.
  • Guilas vs. Judge of the CFI of Pampanga, G.R. No. L-26695 (Jan. 31, 1972) — Cited for the rule that a preterited heir should demand his share through a proper motion in the same probate proceedings, not through an independent action. Followed.
  • Maningat vs. Castillo, 75 Phil. 532 — Cited for the proposition that it is a function of the probate court to determine who the heirs are and the amount or proportion of their respective shares. Followed.
  • Serrano vs. Chanco, 5 Phil. 431 — Cited as the source of the rationale for the exclusive jurisdiction rule in estate settlement. Followed.
  • Lajom vs. Viola, 73 Phil. 563; Ramirez vs. Gmur, 42 Phil. 855; Rodriguez vs. Dela Cruz, 8 Phil. 665; Quion vs. Claridad, 74 Phil. 100 — Cited by petitioner but distinguished and held inapplicable, as those actions were filed by preterited heirs after probate or partition proceedings had been closed or terminated, unlike the present case where the proceedings were still pending.

Provisions

  • Section 1, Rule 73, Rules of Court — Provides that the court first taking cognizance of the settlement of the estate of the deceased exercises jurisdiction to the exclusion of all other courts. Applied to hold that Branch VIII, where Special Proceedings No. 63866 was pending, had exclusive jurisdiction over all matters incident to Rosina's estate, including the validity of the sale of estate properties and the declaration of heirs.

Notable Concurring Opinions

Reyes, J.B.L., Makalintal, Zaldivar, Teehankee, Barredo, and Antonio, JJ., concurred.