G.R. No. 230404 . January 31, 2018.
IN THE MATTER OF THE INTESTATE ESTATE OF REYNALDO GUZMAN RODRIGUEZ; ANITA ONG TAN, Petitioner, vs. ROLANDO C. RODRIGUEZ, ET AL., Respondents.

FACTS

Respondents are the heirs of the spouses Reynaldo and Ester Rodriguez. Petitioner Anita Ong Tan was a co-depositor with Reynaldo in a joint bank account at BPI. Upon Reynaldo’s death, a dispute arose over the ownership of the funds in this account. Anita filed a petition for the settlement of Reynaldo’s intestate estate, primarily to resolve the claim over the joint account funds. She asserted exclusive ownership, presenting evidence that the source of the deposit was a manager’s check drawn from her personal account at East West Bank.
The Regional Trial Court (RTC), acting as an intestate court, ruled in favor of Anita, finding she had sufficiently rebutted the presumption of co-ownership and directing the estate administrator to release the entire account proceeds to her. The Court of Appeals (CA) reversed this decision. The CA held that Anita failed to overturn the legal presumption of equal co-ownership for joint accounts, thus modifying the RTC order to a 50-50 division between Anita and the estate of Reynaldo.

ISSUE

Whether the Court of Appeals erred in declaring Anita and the late Reynaldo as co-owners with equal shares in the joint bank account despite the evidence presented by Anita.

RULING

The Supreme Court granted the petition, reversing the CA and reinstating the RTC’s decision. The legal logic proceeds from the established rule that a joint account creates a presumption of equal co-ownership under Article 485 of the Civil Code. However, this presumption is rebuttable. The Court found that Anita successfully presented clear and convincing evidence—specifically a debit memo and corroborating bank manager testimony—to prove that the funds originated exclusively from her separate account. This evidence substantiated her claim of sole ownership, thereby overcoming the statutory presumption.
Furthermore, the Court addressed the procedural capacity of the intestate court to adjudicate the ownership issue. While a probate court generally has limited jurisdiction and cannot definitively rule on title, an exception applies when the parties voluntarily submit the issue for resolution. Here, the respondents, by seeking affirmative relief in their claim over the funds to the exclusion of Anita, impliedly consented to the intestate court’s jurisdiction over the ownership question. Thus, the trial court validly exercised its authority to resolve the matter.