Maloles II v. Phillips, G.R. No. 129505 & G.R. No. 133359, February 14, 2000
### Facts:
On July 20, 1995, Dr. Arturo de Santos, residing in Makati City, filed a petition for the probate of his will in the Regional Trial Court of Makati (Branch 61), docketed as Sp. Proc. No. M-4223. Dr. De Santos asserted he had no compulsory heirs and designated the Arturo de Santos Foundation, Inc. as his sole legatee and devisee. The will, managed by executrix Pacita de los Reyes Phillips, was attached to the petition. The approximate value of the estate was at least P2,000,000.00.
On February 16, 1996, Judge Fernando V. Gorospe, Jr. granted the petition, confirming the will’s compliance with legal requirements and Dr. De Santos’ sound mind status. Shortly after, Dr. De Santos passed away on February 26, 1996.
On April 3, 1996, Octavio S. Maloles II moved to intervene, claiming to be Dr. De Santos’ nearest of kin and a creditor. Maloles sought reconsideration of the probate order, contending for letters of administration. Concurrently, Pacita Phillips filed for letters testamentary in Branch 61, later moving the petition to Branch 65. Judge Salvador Abad Santos of Branch 65 appointed her as special administrator on June 28, 1996. Maloles again sought to intervene in this new proceeding.
Procedural conflicts ensued between Branches 61 and 65 over jurisdiction, eventually leading to Maloles’ denied motion to intervene in Branch 61 transferring to the Court of Appeals which ruled against him. Phillips’ subsequent attempts to issue letters testamentary from Branch 65 and Maloles’ repeated opposition formed the basis of the extension litigation.
### Issues:
1. Did Branch 61 of RTC-Makati lose jurisdiction over the probate proceeding upon the allowance of the will?
2. Did Branch 65 acquire jurisdiction over the petition for issuance of letters testamentary?
3. Did petitioner Octavio S. Maloles II possess the right to intervene and oppose the petition for issuance of letters testamentary?
4. Was Pacita Phillips guilty of forum shopping by filing her petition with Branch 65 while proceedings were pending in Branch 61?
### Court’s Decision:
**First Issue:**
The Supreme Court ruled that Branch 61 lost jurisdiction once it allowed the will during Dr. De Santos’ lifetime. Only the validity of the will had been established at that stage, postponing estate administration until the testator’s death. Consequently, a new or related petition must follow, making Branch 65’s proceedings valid.
**Second Issue:**
Given the unitary nature of the judicial system where multiple branches are considered part of a single court (RTC of Makati City), Branch 65 properly acquired and exercised jurisdiction over the petition for letters testamentary.
**Third Issue:**
The petitioner, Maloles, was determined not to have a direct interest as an heir or creditor significant enough to intervene. His kinship did not classify him as a compulsory heir, and his creditor claim was deemed belated and unsupported as per Rule 79, §1.
**Fourth Issue:**
The court found no merit in the forum shopping charge against Phillips. The probate proceedings and the petition for letters testamentary were legally distinct. The probate order, once addressed for extrinsic validity, did not preclude subsequent administrative or testamentary proceedings filed by Phillips.
### Doctrine:
The critical doctrine reiterated is that probate proceedings initiated by the testator are limited to ascertaining the extrinsic validity of the will. Full administrative jurisdiction and subsequent actions, like issuing letters testamentary or estate administration, only commence posthumously.
### Class Notes:
**Key Elements:**
1. **Probate Jurisdiction**: Establishes validity of the will – extrinsic factors.
2. **Letters Testamentary**: Issued posthumously, essential for estate administration.
3. **Compulsory Heirs**: Decedents without them can bequeath entire estates freely.
4. **Intervention Rights**: Requires direct, material interest – primarily heirs or creditors.
5. **Unitary Judicial System**: Courts within the same regional jurisdiction can coordinate proceedings.
**Statutory Provisions:**
– **Civil Code, Art. 838**: Probate validity for living testators.
– **Rules of Court, Rule 76 & 79**: Probate guidelines and intervention criteria.
**Simplified Application:**
In probate cases involving pre-death petitions by testators, extrinsic validity suffices for initial procedures; complete estate administration waits until postmortem confirmation. Intervenors must show immediate, direct interest, namely as compulsory heirs or documented creditors.
### Historical Background:
The case provides context on adapting procedural formalities for will probate during a testator’s life—a mechanism recently institutionalized by specific legal provisions (Civil Code and Rules of Court) to preempt disputes, streamline probate authenticity verification, and accommodate the varying operational contexts of the Philippine judicial structure.
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