**Facts:**
1. **Death of Decedents:** Reynaldo Rodriguez and Ester Rodriguez passed away on August 27, 2008, and September 11, 2004, respectively, leaving properties for their children, which include respondents Rolando, Racquel, Rosalinda, Reynaldo Jr., Ester, Rafael, and Reynest Rodriguez.
2. **Extrajudicial Settlement:** Respondents executed an extrajudicial settlement of their parents’ estate on February 13, 2009.
3. **Joint Account:** Anita Ong Tan had a joint account with Reynaldo under the Bank of the Philippine Islands (BPI), account number 003149-0718-56, which remained active after Reynaldo’s death.
4. **Action by BPI:** On August 31, 2009, BPI notified Anita that the account would become dormant if no transactions were made.
5. **Dispute Issue:** Anita attempted to withdraw funds from the joint account but BPI required an extrajudicial settlement of the heirs, which respondents refused to sign, claiming the funds belonged to Reynaldo.
6. **Submission of Claims:** Respondents submitted documents to BPI for the release of half of the funds in the account, causing BPI to withhold release due to conflicting claims.
7. **Court Proceedings:** Anita filed a petition in 2011 for the settlement of Reynaldo’s intestate estate and for the issuance of letters of administration to a neutral party. She claimed the funds were exclusively hers, presented evidence including a Debit Memo from East West Bank and testimony from East West Branch Manager Mineleo Serrano.
8. **Motion to Dismiss:** Respondents moved to dismiss, arguing the funds belonged to Reynaldo.
9. **RTC Ruling:** In 2014, the RTC appointed Rolando Rodriguez as the administrator of the estate. The RTC ruled in favor of Anita on March 13, 2015, determining she sufficiently rebutted the presumption of co-ownership.
10. **Appeals:** Respondents’ motion for reconsideration was denied. They appealed to the CA, which reversed the RTC decision on June 13, 2016, splitting the joint account funds equally between Anita and respondents.
11. **Final Appeal:** Anita’s motion for reconsideration was denied, prompting her to appeal to the Supreme Court.
**Issues:**
1. Whether the Court of Appeals erred in declaring Anita and Reynaldo as co-owners of the joint account deposits despite the evidence provided by Anita.
**Court’s Decision:**
1. **Nature of Joint Accounts:** The Supreme Court established that the depositors of a joint account are presumed equal co-owners unless proven otherwise (Article 485, Civil Code).
2. **Ownership of Funds:** The Supreme Court agreed with the RTC that Anita provided sufficient evidence to prove that she was the sole owner of the funds in the joint account. The amount in the account matched precisely the amount withdrawn from her East West Bank account and no transactions occurred post-deposit that suggested common ownership.
3. **Respondents’ Failure:** The respondents’ inability to include the joint account in the extrajudicial settlement inventory weakened their claim.
4. **Probate Jurisdiction:** The probate court’s limited jurisdiction could address ownership questions due to the implied consent of both parties, signifying that the trial court’s determination was appropriate.
5. **Reversal of CA Decision:** The Supreme Court found that the CA had erred in reversing the RTC decision. Thus, reinstatement of the March 13, 2015 RTC order was warranted, granting sole ownership of the joint account funds to Anita.
**Doctrines:**
1. **Presumption of Co-Ownership in Joint Accounts:** Under Article 485 of the Civil Code, joint accounts are presumed to reflect equal ownership unless rebutted with substantial evidence.
2. **Probate Court Jurisdiction:** The probate court can adjudicate questions of ownership if all parties consent, either expressly or impliedly.
**Class Notes:**
– **Key Elements:** Co-ownership in joint accounts (Art. 485, Civil Code); Evidentiary standards for rebutting co-ownership; Probate court jurisdiction issues.
– **Statutory Provisions:** Article 485, Civil Code: “The share of the co-owners…shall be presumed equal, unless the contrary is proved.”
– **Application:** Evidence and judicial discretion in probate matters can adjudicate ownership disputes if both parties seek affirmative relief.
**Historical Background:**
The case provides context for understanding joint account disputes within Philippine succession law and the handling of intestate estates. It underscores the importance of joint account holders providing sufficient proof to establish their exclusive claims over joint deposits, amplifying judicial precedents on co-ownership in the absence of a survivorship agreement. This judicial analysis sheds light on the evolving interpretations of co-ownership principles and probate jurisdiction in Philippine jurisprudence.
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