**Facts:** The case revolves around the intestate estate of Ismael Reyes, who passed away on April 18, 1973. Prior to his death, a parcel of land owned by Ismael in Tandang Sora, Quezon City, had been levied and eventually forfeited by the Bureau of Internal Revenue (BIR) due to unresolved tax liabilities. Oscar Reyes, one of Ismael’s sons, managed to redeem the property in 1976 by availing of a BIR tax amnesty and settling the tax debt. Further complications arose when the Reyes family was informed of an impending public auction for another set of properties, known as the Arayat properties, in 1982 due to unpaid real estate taxes. Oscar again settled these liabilities in 1986.
On May 10, 1989, Cesar Reyes, another of Ismael’s sons, filed a petition with the Regional Trial Court (RTC) of Quezon City for the issuance of letters of administration for Ismael’s estate, which he claimed included 50% of the Arayat properties. Oscar opposed this claim, asserting that he had acquired the properties through redemption and purchase. The RTC eventually appointed Cesar as administrator, leading Oscar to oppose the inclusion of the Arayat properties in the estate, arguing that he acquired them through his own efforts and funds.
Oscar’s motion for reconsideration was denied by the RTC, prompting him to appeal to the Court of Appeals (CA), which affirmed the RTC’s decision. After Oscar’s death, his heirs continued the legal battle by filing a petition for review on certiorari before the Supreme Court.
**Issues:**
1. Whether the Arayat properties should be included in the inventory of Ismael Reyes’s estate.
2. Whether the probate court (RTC) has jurisdiction to conclusively determine the issue of ownership of the properties in question.
**Court’s Decision:**
The Supreme Court denied the petition for review, upholding the CA’s decision. The Court clarified that while a probate court has the authority to determine what properties should be included in the estate for inventory purposes, this determination is provisional and not conclusive on the issue of ownership. The justices ruled that the determination of ownership is beyond the probate court’s jurisdiction and must be resolved in a separate action in an appropriate court. They also noted the absence of consensus among all parties interested in the property, which means the probate court could not have taken cognizance of the issue of ownership even if it wanted to.
**Doctrine:** The probate court’s determination of what properties belong to the deceased’s estate is provisional and not conclusive on the issue of ownership. Questions of ownership are outside the probate court’s jurisdiction and must be resolved in a separate action.
**Class Notes:**
1. **Probate Court Jurisdiction:** Limited to matters related to the settlement of estates, probate of wills, and the appointment/removal of estate administrators. It does not include final determination of property ownership.
2. **Property Inclusion in Estate Inventory:** Provisional and subject to final decision in a separate ownership dispute.
3. **Submission to Probate Court’s Adjudication:** Limited scenarios where disputes over ownership may be entertained by the probate court, typically requiring the consent of all parties with an interest in the property.
**Historical Background:** The case underscores the complexities involved in intestate succession and the limits of probate court jurisdiction in the Philippines. It highlights the legal distinction between the settlement of an estate (which includes identifying assets that may be part of the estate) and the separate, substantive question of ownership, which may necessitate independent legal action.
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