**Facts:**
On September 15, 1994, Eduardo G. Agtarap (Eduardo) filed a verified petition before the Regional Trial Court (RTC) Branch 114, Pasay City, for the judicial settlement of the estate of his late father Joaquin Agtarap (Joaquin), who passed away intestate on November 21, 1964. Joaquin was married twice, first to Lucia Garcia (Lucia), with whom he had three children: Jesus, Milagros, and Jose. Lucia died on April 24, 1924. Joaquin later married Caridad Garcia (Caridad) on February 9, 1926, and they had three children: Eduardo, Sebastian, and Mercedes.
Upon Joaquin’s death, he left two parcels of land in Pasay City. Joseph, a grandson of Joaquin, had been leasing and improving these properties and retaining the income from them. Eduardo sought the appointment as special administrator to manage the estate assets, pending the appointment of a regular administrator, and requested the court to confirm the heirs and distribute the estate among them.
On December 28, 1994, Sebastian filed a comment, accepting the allegations of the petition and agreeing to Eduardo’s appointment as special administrator. However, grandchildren Joseph, Gloria, and Teresa opposed Eduardo’s appointment, claiming the properties belonged to the conjugal partnership of the first marriage. They argued that Eduardo was unfit to be appointed as administrator and proposed Joseph instead.
On February 16, 1995, the RTC appointed Eduardo as the regular administrator. Abelardo Dagoro later intervened, asserting his position as Mercedes’s surviving spouse. The parties submitted proposed projects for partition, and on October 23, 2000, the RTC issued an Order of Partition distributing the estate, which amounted to a net worth of P14,177,500.00 among Joaquin’s heirs.
Respondents filed motions for reconsideration. The RTC granted the motion by Joseph and Teresa, declaring properties belonging to the conjugal partnership of Joaquin and Lucia, thus modifying the partition plan. Eduardo and Sebastian appealed to the Court of Appeals (CA).
On November 21, 2006, the CA dismissed the appeals, affirming the RTC’s modified partition order. Eduardo and Sebastian filed motions for reconsideration, which were subsequently denied. Hence, Eduardo and Sebastian petitioned the Supreme Court.
**Issues:**
1. Whether the RTC, as a probate court, had jurisdiction to resolve questions of ownership concerning the estate properties.
2. Whether the properties covered by TCT Nos. 38254 and 38255 belonged to the conjugal partnership of Joaquin and Lucia.
3. Whether the legitimacy of Joseph and Teresa as heirs was sufficiently established.
4. Whether the Court of Appeals erred in distributing the inheritance of Milagros, considering her alleged last will and testament.
5. Whether the Court of Appeals correctly addressed issues pertaining to the settlement of multiple estates within one proceeding.
**Court’s Decision:**
The Supreme Court held the following:
1. **Jurisdiction of the RTC**: The RTC, as an intestate court, had jurisdiction to resolve the ownership issues since all parties involved were heirs of Joaquin, and no third-party rights were affected. The determination of ownership was necessary for the liquidation of the conjugal property to ascertain the estate’s value.
2. **Ownership of Properties**: The subject properties were part of the conjugal partnership between Joaquin and Lucia. Evidence showed that the properties were covered by titles initially registered to Joaquin and Lucia, and subsequent title amendments to list Caridad did not nullify Lucia’s conjugal share.
3. **Legitimacy of Heirs**: Joseph and Teresa were valid heirs of Jose, and thus rightful heirs of Joaquin. Both the RTC and the CA found their legitimacy adequately substantiated despite Sebastian’s contestation.
4. **Inheritance Share of Milagros**: The distribution of Milagros’s share in Joaquin’s estate was erroneous due to the pending probate of her will, which supposedly bequeathed her share to Eduardo. Thus, her share would not be distributed until the probate court conclusively determines the legitimacy of her will.
5. **Settlement of Multiple Estates**: Although the CA had included distributions that effectively settled other related estates, such actions were a necessary consequence of settling Joaquin’s estate. The distribution adhered to procedural norms prescribed for such cases under existing laws.
**Doctrine:**
1. A probate court can provisionally determine ownership issues of estate properties in the context of heirs’ claims, without prejudice to later, separate determinations.
2. Conjugal properties remain conjugal, unless conclusively demonstrated otherwise, and titles reflecting marital bonds are not definitive proof of sole or conjugal ownership.
3. Legitimacy of heirs must be established with clear evidence, and probate courts can rule on heirship issues where necessary.
**Class Notes:**
– **Conjugal Property**: Assets acquired during the marriage unless proven otherwise.
– **Intestate Proceedings**: Legal process of settling a deceased person’s estate without a will, including inventory and distribution among heirs.
– **Probate Jurisdiction**: Limited to matters related to the estate unless exceptions justify resolving ownership disputes within probate.
– **Inheritance Law**: Heirs inherit representation; legitimacy affects claims; testate succession prevails over intestate.
**Historical Background:**
This case epitomizes the complex intertwining of multiple estates and marriages, highlighting the probate courts’ integral role in verifying property rights and heir legitimacy. It reflects the procedural nuances and rigorous evidentiary standards that underpin estate settlement within Philippine jurisdiction, emphasizing concurrency between historical title interpretation and modern statutory enforcement.
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