**Facts:**
The core of this case revolves around the estate of the late spouses Teodoro T. Reselva and Lucrecia Aguirre Reselva, whose property, a house and lot located at 173 Ilaw St., Balut, Tondo, Manila, became the subject of a legal dispute among their heirs. Lucrecia died on May 13, 1987, followed by Teodoro on April 11, 1989. Teodoro left behind a holographic will that was probated, appointing Milagros R. Cortes as the executrix. Cortes then sought judicial intervention to eject Menandro A. Reselva, one of Teodoro’s heirs who occupied the disputed property, in order to take possession on behalf of the estate. This request was initially granted by the probate court but was overturned by the Court of Appeals (CA), which ruled that the probate court exceeded its jurisdiction.
The procedural path to the Supreme Court began with Cortes’s challenge to the CA’s decision via a petition for review on certiorari. The CA had decided that probate courts have a limited jurisdiction that does not extend to the adjudication of title or possession over properties claimed by heirs.
**Issues:**
1. Whether the probate court has jurisdiction to order an heir to vacate property claimed as part of the decedent’s estate.
2. Whether the dispute concerning the property falls under the jurisdiction of the probate court when it involves the liquidation of the conjugal partnership assets of the decedent and his deceased spouse.
**Court’s Decision:**
The Philippine Supreme Court set aside the CA’s ruling and remanded the case to the trial court for further proceedings. The Court clarified that while probate courts generally cannot determine title to or possession of properties claimed to be part of an estate, an exception exists when the dispute is among heirs of the decedent. Due to the parties involved being heirs, and thus not outside parties, the probate court was deemed competent to decide upon the question of ownership. The Court also highlighted that Menandro’s claim did not contradict the decedent’s interest, suggesting co-ownership rather than sole ownership, further supporting jurisdiction by the probate court. Importantly, the Court pointed out that the case required the liquidation of the conjugal partnership of Teodoro and Lucrecia Reselva as part of the estate settlement process, squarely falling under the probate court’s jurisdiction per relevant procedural rules.
**Doctrine:**
This case reinforces the doctrine that probate courts have limited jurisdiction to adjudicate titles or rights of possession over estate properties claimed by third parties. However, an exception exists when all disputing parties are heirs to the decedent, allowing the probate court to resolve questions of property ownership within the context of estate settlement. Furthermore, the case reaffirms that the probate court has jurisdiction over the liquidation of the conjugal partnership assets within estate proceedings.
**Class Notes:**
– **Probate Jurisdiction Limitation:** Probate courts cannot generally adjudicate title or possession of estate properties claimed by external parties.
– **Heirs Exception:** If disputants are heirs, probate courts can resolve ownership issues.
– **Conjugal Partnership Liquidation:** Pertinently, probate courts are empowered to liquidate conjugal partnerships as part of settling the estate, per Rule 73, Section 2 of the Revised Rules of Court.
– **Key Statutory Provision:** The jurisdiction of probate courts to liquidate conjugal partnership assets is explicitly provided under Rule 73, Section 2 of the Revised Rules of Court.
**Historical Background:**
This case underscores the nuances in Philippine probate law, especially the delineation of probate courts’ jurisdiction concerning estate property disputes. It highlights the judicial approach in accommodating heirs’ disputes within probate proceedings, aimed at simplifying and expediting the settlement of estates, particularly pertinent for parties of modest means. Additionally, it reflects the legal system’s adaptation to the socio-economic realities of the parties involved, facilitating access to justice by allowing certain disputes to be resolved within the probate process rather than through separate, potentially burdensome litigation.
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