**Facts:**
On March 22, 1987, Manolito de Guzman passed away in Makati, Metro Manila, leaving behind an estate and a surviving spouse, Elaine G. de Guzman, and two minor children. Elaine filed a petition for the settlement of Manolito’s intestate estate at the Makati RTC, claiming the estate included conjugal properties and was worth around P4,000,000. She requested to be appointed as an administratrix. Before the court issued notice to all interested parties as required, Elaine filed motions for a writ of possession over certain vehicles and to be appointed as special administratrix. Despite the absence of proper notice, the trial court granted these motions. Pedro de Guzman, father-in-law of Elaine, contested the motions, leading to a standoff when deputies attempted to enforce the court’s orders. Subsequently, Pedro filed a petition with the Supreme Court contesting the RTC’s actions for lacking proper notice and due process.
**Issues:**
1. Whether a probate court may appoint a special administratrix and issue a writ of possession for alleged properties of the decedent without first serving notice to all interested parties as required.
2. Whether the actions taken by the probate court without due notice to interested parties violate the due process of law.
3. Whether the respondent judge should be disqualified from further presiding over the case.
**Court’s Decision:**
The Supreme Court ruled in favor of Pedro de Guzman, holding that the probate court acted prematurely in appointing a special administratrix and issuing writs of possession without following the mandatory notice requirements outlined in the Rules of Court. It emphasized the necessity of proper notice to interested parties to ensure that no person is deprived of their property without due process. The Court differentiated between the probate court’s jurisdiction over the proceedings and over the interested parties, stating that the latter requires strict adherence to notice requirements for jurisdiction to be properly established. Thus, the actions of the probate court were declared null and void, and the case was ordered to be remanded for proper proceedings with notice to all interested parties. Also, considering the respondent judge’s request for voluntary inhibition, the Court decided that re-raffling the case to another branch would serve the interests of justice.
**Doctrine:**
The Supreme Court reiterated the doctrine that notice through publication of a petition for the settlement of a deceased person’s estate is jurisdictional. The absence of such notice makes subsequent court orders affecting other persons void and subject to annulment, safeguarding against the deprivation of property without due process.
**Class Notes:**
1. Probate Jurisdiction vs. Jurisdiction over Interested Parties: The probate court has jurisdiction over estate proceedings once a petition properly alleging jurisdictional facts is filed. However, jurisdiction over interested parties requires serving notice as mandated, ensuring all interested individuals are brought within the court’s jurisdiction.
2. Importance of Notice: Notice requirements in probate proceedings are critical for due process, ensuring no deprivation of property rights without proper judicial process.
3. Role of Special Administratrix: A special administratrix is appointed to preserve the estate until a regular administrator is appointed. Their appointment and actions must follow established legal procedures, including notice to interested parties.
4. Voluntary Inhibition of Judges: Judges should voluntarily inhibit themselves from presiding over cases where their impartiality might reasonably be questioned to maintain public confidence in the judiciary’s fairness and impartiality.
**Historical Background:**
This case reflects the Philippine judicial system’s commitment to due process, especially in probate matters, insisting on adherence to procedural requirements for the protection of all interested parties’ rights. It underscores the importance of balancing immediate actions to preserve an estate with the fundamental rights of individuals to due process and fair hearing.
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