### Facts:
The case unraveled from the dispute over the estate of the late Filipino novelist Esteban Javellana, Jr., who died single and without direct heirs, leaving his estate mainly inherited from his mother, Salustia Solivio. Celedonia Solivio, his maternal aunt, and Concordia Javellana Villanueva, his paternal aunt, emerged as the surviving relatives. Post Esteban Jr.’s death, there was consensus between Celedonia and Concordia to honor Esteban Jr.’s wishes by placing his estate into a foundation aimed at helping indigent students. Celedonia, entrusted with the task, filed for special administration and was initially declared the sole heir to fast-track the foundation’s formation. However, Concordia later contested Celedonia’s sole heirship in a separate civil case asserting her right to half of the estate. After the trial court’s decision favoring Concordia, and subsequent affirmation by the Court of Appeals, Celedonia filed for review in the Supreme Court, questioning jurisdiction, the role of extrinsic fraud, the application of reserva troncal, and Concordia’s right to the estate despite the agreement to form a foundation.
### Issues:
1. Jurisdiction of the RTC to adjudicate the estate while probate proceedings were pending.
2. Extrinsic fraud as a factor in Concordia’s late intervention in the probate process.
3. Application of reserva troncal to the properties inherited by Celedonia.
4. Concordia’s entitlement to the estate post-agreement to form a foundation.
### Court’s Decision:
The Supreme Court granted Celedonia’s petition, setting aside the decisions of the lower courts. It declared:
1. The probate court had exclusive jurisdiction over the estate, and the separate action filed by Concordia was improperly lodged.
2. Concordia’s claim of extrinsic fraud was unwarranted as she had both actual and constructive notice of the probate proceedings and had initially agreed to the formation of the foundation.
3. The doctrine of reserva troncal did not apply as the properties in question were not inherited by an ascendant from a descendant but the other way around.
4. Although declaring Concordia an heir entitled to half of Esteban’s estate, her prior agreement to dedicate the estate to the “Salustia Solivio Vda. de Javellana Foundation” was binding, thus, the entire estate was to be conveyed to the foundation, with both Celedonia and Concordia serving as trustees.
### Doctrine:
– The decision reiterated the doctrine of exclusive jurisdiction of probate courts over estate disputes amid ongoing probate proceedings, emphasizing the inappropriate nature of filing separate actions that could interfere with or contradict probate court rulings.
– It also clarified the non-applicability of the reserva troncal provision in instances where inheritance flows from an ascendant to a descendant.
### Class Notes:
Key Concepts:
– **Jurisdiction of Probate Courts**: Probate courts exclusively handle estate distribution and related disputes until all processes including inventory, accounting, and final distribution are conclusively settled.
– **Extrinsic Fraud**: Represents actions preventing a party from a fair case presentation. The claim of extrinsic fraud requires substantial evidence indicating restricted participation in legal proceedings to the detriment of the aggrieved party.
– **Reserva Troncal**: A legal concept applicable only when properties ascendently inherited from a descendant were originally acquired from another ascendant, brother, or sister. It obliges the inheriting ascendant to reserve the property for relatives within the third degree from the line of acquisition.
– **Judicial Admission**: Statements acknowledged as true by a party during legal proceedings, with binding effects unless successfully withdrawn or impugned.
### Historical Background:
This case touches on a unique intersection of familial commitments to a deceased relative’s unstated yet respected wishes and legal principles guiding inheritance disputes. It highlights how personal intentions for charitable foundations related to estate legacies intersect with familial rights and responsibilities, underscoring the complexities when legal provisions meet moral obligations.
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