**Facts:**
1. Jayme Morales and Telesfora Garzon, who both died intestate, owned a parcel of land known as Lot No. 9217-A in Barangay Sto. Tomas, Laoag City, covered by TCT No. T-37139.
2. They had four children: Vicente, Simeon, Jose and Martina, who have since been survived by their respective heirs.
3. The respondent, Astrid Morales Agustin, initiated a complaint for partition of the property, asserting her co-ownership rights by virtue of her succession from her father, Simeon Morales.
4. Some heirs of Jose Morales supported the partition, but Ernesto Morales contested it, arguing the property had already been conveyed to him by Simeon and Leonila Morales, Astrid’s parents.
5. Throughout the trial before the RTC, a series of procedural motions were presented, including answers admitting claims, motions to dismiss for lack of jurisdiction, affidavits, and a claim that RTC could partition the property without an estate settlement process.
6. The RTC rendered a summary judgment for partitioning Lot No. 9217-A on November 22, 2013.
7. Ernesto Morales’ heirs elevated the case to the CA, which affirmed the RTC decision, dismissing concerns over missing summons and clarifying the applicability of summary judgment.
8. The petitioners filed a motion for reconsideration, which the CA subsequently denied, prompting the case to be elevated to the Supreme Court.
**Issues:**
1. Whether the RTC could proceed with the partition despite the absence of an estate settlement process.
2. Whether the application of summary judgment without party motion and hearing was proper.
3. Whether jurisdiction was valid given the alleged improper service of summons to indispensable parties.
**Court’s Decision:**
1. **Jurisdiction and Service of Summons:** The Supreme Court upheld the CA’s validation of proper service of summons. The partition of real estate being an action quasi in rem, it suffices that the court had jurisdiction over the res. Moreover, there was substantial compliance with procedural due process.
2. **Application of Summary Judgment:** The Supreme Court found that the RTC’s rendering of a summary judgment was improper, citing that genuine issues of material fact were raised, making a trial necessary. The lack of a party’s motion for summary judgment and a required hearing further invalidated the RTC’s summary judgment, resulting in reversible error.
3. **Necessity of an Estate Settlement:** The Supreme Court concurred that partition could proceed without prior estate settlement since the decedents’ estates were free of debts. However, the Court emphasized the need for collation and proper adjudication through a full trial to address all co-heirs’ claims and ensure fair distribution according to law.
**Doctrine:**
1. **Partition and Succession:** Partition of estate properties can be judicially determined without a separate estate settlement proceeding if decedents died intestate and left no debts.
2. **Summary Judgment Requirements:** A summary judgment requires the absence of genuine issues and necessitates a motion and hearing to ensure procedural fairness.
3. **Jurisdiction in Quasi in Rem Proceedings:** The court needs jurisdiction over the res, and substantial compliance with due process suffices for jurisdiction in partition actions.
4. **Collation Requirement in Succession:** Properties received by heirs via gratuitous title during the decedent’s lifetime need to be brought to the mass of the estate for a fair partition among heirs.
**Class Notes:**
– **Partition in Successions:** Governed by Articles 777, 1082, and 1061 of the Civil Code. Title to inheritance vests upon decedent’s death.
– **Summary Judgment:** Under Rule 35, requires motion, hearing, and absence of genuine material fact issues. Cases: Wood Technology Corp. v. Equitable Banking; Caridao v. Estenzo.
– **Jurisdiction in Quasi in Rem Actions:** Requires jurisdiction over the res, not necessarily over all parties provided significant due process.
– **Estate Collation:** Compulsory heirs must account for any properties received gratuitously to ensure equitable distribution under Article 1061.
**Historical Background:**
This partition case reflects the broader socio-legal context where familial disputes over inherited property have been a recurring theme in Philippine jurisprudence. It underscores the Philippine judiciary’s dedication to observance of procedurally sound methods while safeguarding heirs’ equitable rights and underscoring formal legal processes in maintaining order amidst complex family legally-bound relations.
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