### Facts:
In 1979, Cadidia Imam Samporna married Mahid Mira-ato Mutilan under Muslim Law. Mahid previously had a son, Mohammad, from another marriage. In 1993, Cadidia consented to Mahid’s marriage to Saphia Mutilan, and in 2003, to another marriage with Sauda Mutilan, both also under Muslim law.
On December 12, 1999, Cadidia purchased two parcels of land in Marawi City from Rodolfo “Boy” Yu Diator, on behalf of his mother Alice Yu Diator. Cadidia executed Deeds of Absolute Sale and Affidavits stating the lands were purchased with her separate funds. Titles for these lands were later issued in Cadidia’s name.
After Mahid’s death in 2007, Saphia initiated a Judicial Settlement of Mahid’s Estate in 2008 at the Shari’a District Court, which appointed Cadidia as the administratrix. However, the parcels of land remained titled in Cadidia’s name and were excluded from Mahid’s estate inventory.
Claiming Mahid actually purchased the lands, Saphia, Sauda, and Mohammad filed a complaint in 2009 at the Regional Trial Court (RTC) of Marawi City to annul the Deeds of Absolute Sale and titles issued to Cadidia. This complaint was dismissed by the RTC in 2010 for lack of merit, ruling the plaintiffs were not parties in interest and failed to implead indispensable parties.
The Court of Appeals affirmed the RTC’s decision, holding that the probate court (Shari’a District Court) had jurisdiction over the matter, and the appeal constituted forum shopping. Additionally, it found the plaintiffs not to be real parties in interest for the annulment action and highlighted the fatal flaw of not impleading indispensable parties.
### Issues:
1. Whether the Shari’a District Court’s exclusion of properties from the deceased’s estate is final and binding, preventing heirs from filing separate civil actions.
2. Whether heirs not party to Deeds of Absolute Sale can be considered real parties in interest in seeking their annulment.
3. Whether the failure to implead indispensable parties warrants dismissal of the case.
### Court’s Decision:
The Supreme Court denied the petition, affirming the decisions of both the RTC and Court of Appeals. It clarified that:
1. **Probate Court Jurisdiction**: The Shari’a District Court rightfully exercised jurisdiction in excluding the properties from Mahid’s estate. The determining of property ownership among heirs falls within its purview, and its judgment on such matters is deemed final. The petitioners’ failure to contest the exclusion constituted acquiescence.
2. **Real Parties in Interest**: The heirs, not being direct parties to the Deeds of Absolute Sale, lacked the substantive interest required to challenge their validity. Their claim as heirs of Mahid did not suffice since the properties were purchased by Cadidia independently of Mahid.
3. **Indispensable Parties**: The absence of indispensable parties, such as the seller and the estate of Mahid, rendered the complaint dismissible. Both lower courts correctly identified this lack of jurisdiction arising from the failure to include these necessary parties.
### Doctrine:
The probate court can decide on title or ownership matters when the parties involved are all heirs, provided that third party rights are unaffected. For disputes involving property ownership within estates, jurisdiction falls squarely within the probate court, and its judgments in such contexts are final.
### Class Notes:
1. **Heirs as Parties in Interest**: Heirs can challenge property ownership within an estate only if they directly engage within probate proceedings and are actual parties to the transactions in question.
2. **Jurisdiction of Probate Court**: Specifically tackles jurisdictional boundaries between probate courts and regular civil courts under Philippine Muslim Law and general civil law — highlighting the probate court’s capacity to resolve estate-related ownership discrepancies among heirs.
3. **Indispensable Parties in Civil Actions**: Emphasizes the importance of including all necessary parties to a dispute in legal actions, without which a case may be dismissed for lack of jurisdiction.
### Historical Background:
This case meticulously delineates the jurisdictional roles between probate and regular courts in the context of property disputes within estate settlements under Philippine Muslim Law, particularly highlighting the intricacies of marital, inheritance, and property rights. It underscores the evolving legal landscapes in accommodating traditional law within the framework of the national legal system, aiming to balance religious customs with statutory requirements.
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