G.R. No. L-59592, February 29, 1984
BLESILO BUAN and FLORENCIO BUAN, JR., Petitioners, vs. HON. FERNANDO S. ALCANTARA, as Judge of the Court of First Instance of Tarlac, and A. NATIVIDAD PARAS-NISCE, Respondents.

FACTS

The case involves the protracted intestate estate proceedings of spouses Florencio P. Buan and Rizalina Paras-Buan, who died in 1953, leaving five minor children. Respondent A. Natividad Paras-Nisce, the sister of the deceased mother, and Bienvenido Buan, the brother of the deceased father, were appointed co-administrators. Over the decades, the administrators engaged in corporate maneuvers that significantly diminished the estate’s assets. Crucially, in 1964, they petitioned for and obtained court approval to waive the estate’s pre-emptive right to subscribe to a capital stock increase of the family’s major asset, Philippine Rabbit Bus Lines, Inc. The administrators and other relatives then personally subscribed to the new shares, reducing the estate’s controlling interest from 99.67% to a mere 35%. The administrators also formed other corporations, like Bupar Motors and Tarlac Development Bank, using estate assets and properties.

FACTS

(Continued)
Petitioners Blesilo Buan and Florencio Buan, Jr., heirs who had reached majority, filed an Omnibus Motion in 1981 praying for the closure of the intestate proceedings, which had been pending for 28 years. They also sought precautionary measures against respondent administratrix Paras-Nisce, alleging mismanagement and conflict of interest. The respondent Judge denied the motion, citing pending suits against the former administrators and the need to resolve exceptions filed by the heirs to the administrators’ actions. The petitioners elevated the case to the Supreme Court via certiorari, arguing that the lower court’s order perpetuated the administration contrary to law.

ISSUE

Whether the respondent Judge committed grave abuse of discretion in denying the motion for closure of the intestate estate proceedings.

RULING

Yes. The Supreme Court granted the petition and set aside the lower court’s order. The legal logic is anchored on the fundamental principle that the settlement of estates is meant to be a summary proceeding, not intended to last indefinitely. The Court held that the pendency of suits against the administrators, which primarily concern their alleged fraudulent or questionable acts in managing estate properties, should not preclude the distribution of the remaining estate assets to the lawful heirs. These suits are personal actions that can proceed independently. To condition the closure of the proceedings on the resolution of all such suits would, as the Court stated, “virtually place the estate under perpetual administration contrary to the intendment of the law.” The estate had been under administration for an unreasonable 28 years, and the heirs, as owners, are entitled to their inheritance. The Court ordered the lower court to distribute the estate assets to the heirs within three months, while allowing the continuation of hearings on the exceptions to the administrators’ actions separately. The administratrix was also directed to render a final accounting.