**Facts:**
1. **Initial Petition:**
– Petitioner Jesusa Dujali Buot (Buot) filed a petition in the Regional Trial Court (RTC) of Panabo City, requesting letters of administration for the estate of the deceased Gregorio Dujali.
– Buot alleged that she, along with other listed heirs, were entitled to Gregorio’s estate and that Roque Dujali (Dujali) had continued to control the properties to the exclusion of the other heirs.
2. **Respondent’s Opposition:**
– Roque Dujali contested Buot’s petition by filing an opposition with a motion to dismiss, arguing Buot’s lack of legal capacity to sue. Dujali posited that Buot failed to attach sufficient proof of her filiation, such as a birth certificate or Gregorio’s marriage certificate to Sitjar Escalona.
– In support, Dujali provided a marriage certificate showing Gregorio was married to his mother, Yolanda Rasay, with no record of a prior marriage to Sitjar Escalona.
3. **Buot’s Rebuttal:**
– Buot responded by asserting the rules only require ultimate facts in pleading, not evidentiary matters.
– She provided a necrological service program listing her as an heir, a certification from the municipal mayor, and an Amended Extrajudicial Settlement that included her as Gregorio’s heir.
4. **Initial RTC Decision:**
– The RTC denied Dujali’s motion to dismiss, reiterating that the issues he raised should be addressed during the trial phase.
5. **Respondent’s Motion for Reconsideration:**
– Dujali sought reconsideration, emphasizing longstanding jurisprudence requiring motions to dismiss based on lack of legal capacity and questioning the validity of the Amended Extrajudicial Settlement.
6. **RTC Reversal and Dismissal:**
– The RTC granted Dujali’s motion for reconsideration, highlighting that the extrajudicial settlement of Gregorio’s estate rendered the judicial administration unnecessary, thus dismissing Buot’s petition.
7. **Buot’s Motion for Reconsideration:**
– Buot filed a motion for reconsideration, arguing it was not a second prohibited motion for reconsideration and presenting that the extrajudicial settlement did not cover the entire estate.
8. **RTC Final Rejection:**
– The RTC dismissed Buot’s motion for reconsideration as a second prohibited motion and refused to reverse its earlier decision.
9. **Supreme Court Petition:**
– Buot petitioned the Supreme Court, challenging the RTC’s orders, specifically arguing procedural errors and inadequate consideration of her reasons for seeking judicial administration.
**Issues:**
1. **Procedural Error:**
– Whether the RTC correctly identified Buot’s motion for reconsideration as a second and thus prohibited motion.
2. **Substantive Merit:**
– Whether Buot’s reasons for petitioning for letters of administration sufficed to override the extrajudicial settlement previously observed.
**Court’s Decision:**
1. **Procedural Issue:**
– The Supreme Court ruled that the RTC erred in finding Buot’s motion for reconsideration a prohibited second motion. It clarified she had filed only her first motion following Dujali’s initial motion for reconsideration.
2. **Dismissal of Petition:**
– The Court upheld the RTC’s dismissal of Buot’s petition on grounds that the estate had been settled extrajudicially per Rule 74, Section 1 of the Rules of Court.
– The Supreme Court reiterated that judicial administration might only be justified by compelling reasons, which Buot’s allegations did not convincingly provide.
**Doctrine:**
1. **Extrajudicial Settlement Rule:**
– Rule 74, Section 1 allows heirs to divide the estate without judicial administration given no debts and unanimity in settlement, subject to certain conditions.
– Judicial administration is non-mandatory and typically unnecessary where extrajudicial settlement or partition can adequately serve heirs’ interests.
2. **Compelling Reason Exception:**
– Judicial administration is viable if heirs cite legitimate and powerful reasons not to pursue ordinary actions for partition, although these must be compelling and specific.
**Class Notes:**
1. **Key Legal Principles:**
– Rule 74, Section 1 of the Rules of Court: Conditions for extrajudicial settlement by heirs.
– Understanding “final resolution” under Rule 52, Section 2 about prohibited second motions for reconsideration.
– The distinction between issues suitable for dismissal and those warranting trial proceedings in estate matters.
2. **Application:**
– Ultimate facts in pleadings vs. evidentiary requirements – Legal distinctions crucial for threshold sufficiency in estate litigation.
– Proving heirs’ entitlements, via litigation or extrajudicial means, ensuring comprehensive estate coverage.
**Historical Background:**
– The case stems from entrenched practices in managing intestate estates in the Philippines, emphasizing judicial efficiency and limited necessity for administration if debts are absent and heirs capable of mutual agreement.
– The judicial restraint in compelling administration enhances effectiveness in estate disputes but underscores the role of alternative legal remedies, meaningful in post-colonial legal evolution and codified by procedural rules.
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