GR 121438; (October, 2000) (Digest)
G.R. No. 121438; October 23, 2000
FELIX UY CHUA, ROBERT IPING CHUA, RICHARD UY CHUA and Atty. FEDERICO C. CABILAO, JR., petitioners, vs. COURT OF APPEALS, SOFIA O. SANCHEZ, assisted by husband FORTUNATO SANCHEZ, respondents.
FACTS
Aida Morada, as administratrix of the estate of her deceased husband Fernando, obtained court approval to sell a parcel of land. On April 15, 1991, she executed a Deed of Absolute Sale in favor of respondent Sofia Sanchez for P1,000,000. The probate court, presided by Judge Abarquez, approved this sale on May 3, 1991. Subsequently, intervenor Atty. Federico Cabilao, representing undisclosed clients (the petitioners), presented a higher offer of P1.5 to P2 million for the same property. Based on this new offer and allegations that the administratrix and Sanchez concealed material facts—specifically, that a P300,000 loan from Sanchez to the estate was deducted from the down payment—Judge Abarquez issued an order on November 15, 1991, revoking his prior approval, declaring the sale to Sanchez void, and later approving a new sale to the petitioners.
ISSUE
Whether the probate court committed grave abuse of discretion in nullifying its final and executory order approving the sale of estate property to Sanchez and subsequently approving a new sale to another buyer.
RULING
Yes, the probate court committed grave abuse of discretion. The Supreme Court affirmed the Court of Appeals’ ruling that the order approving the sale to Sanchez had already become final and executory. An order approving a sale of estate property, if not appealed within the reglementary period, attains finality and becomes immutable. The probate court thus lost jurisdiction to alter, amend, or revoke that final order. The alleged concealment by the administratrix and Sanchez, even if true, did not justify the revocation, as the proper remedy for an aggrieved party would have been a separate action to annul the sale on grounds of fraud, not a collateral attack in the same probate proceeding after finality. The act of nullifying a final order and approving a new sale based on a higher subsequent offer constituted an oppressive exercise of judicial authority, amounting to a lack or excess of jurisdiction correctible by certiorari. Consequently, the Deed of Sale in favor of Sanchez was upheld as valid and binding.