G.R. No. 244542 , June 28, 2021
MA. CONCEPCION ALFEREZ, ANTONIO S. ALFEREZ, AND ESPERANZA ALFEREZ EVANS, PETITIONERS, VS. SPOUSES EXEQUIEL AND CELESTINA CANENCIA, NORMA A. ALFORQUE, AND TERESA A. ALFORQUE, RESPONDENTS.

FACTS

Federico J. Alferez died intestate on September 23, 1980, survived by his spouse Teodora and children Ma. Concepcion, Antonio, and Esperanza (petitioners). Ma. Concepcion filed a Petition for Issuance of Letters of Administration for Federico’s intestate estate, docketed as Special Proceedings No. 437, and was appointed administratrix. The estate included specific parcels of land. On January 15, 1982, Teodora and petitioners executed an Extrajudicial Settlement with Donation, whereby Teodora donated her conjugal shares in certain lots to her children, making Ma. Concepcion, Antonio, and Esperanza the exclusive owners of specific lots. To settle Federico’s outstanding bank debts, Ma. Concepcion, as administratrix, filed an Urgent Motion to sell properties, supported by Special Powers of Attorney from Antonio and Esperanza authorizing her to sell their respective lots. The court authorized the sale. On October 8, 1985, Ma. Concepcion executed a Deed of Sale with Assumption of Mortgage with respondents, covering the properties adjudicated to petitioners for a consideration of P300,000.00. Petitioners later filed an action for Annulment and/or Declaration of Nullity of the Deed, Recovery of Possession, Damages, and Attorney’s Fees, alleging that the Deed was intended to cover only Federico’s half of the estate, not the entire property including Teodora’s share, and that respondents acted in bad faith. The RTC rendered a Judgment on May 17, 2016, declaring the Deed valid. Petitioners appealed to the CA.

ISSUE

Whether the Regional Trial Court (RTC) had jurisdiction over the action for Annulment and/or Declaration of Nullity of the Deed of Sale with Assumption of Mortgage, Recovery of Possession, Damages, and Attorney’s Fees, considering that the properties involved were part of a decedent’s estate under ongoing intestate proceedings.

RULING

The Court of Appeals declared the RTC Judgment void for lack of jurisdiction. The Supreme Court affirmed this ruling. The properties subject of the sale were part of the estate of Federico J. Alferez, and the intestate proceedings (Special Proceedings No. 437) were still pending. Jurisdiction over the settlement of the estate of a decedent is vested in the court where the intestate proceedings are filed, to the exclusion of all other courts. The pendency of the intestate proceedings precluded the RTC from taking cognizance of the action for annulment of the deed of sale involving the same estate properties. The issue of the validity of the Deed of Sale should be resolved within the intestate proceedings, not in a separate action. Therefore, the RTC acted without jurisdiction.