GR 184237; (September, 2016) (Digest)
G.R. No. 184237 . September 21, 2016.
HENRY H. TENG, PETITIONER, VS. LAWRENCE C. TING, EDMUND TING AND ANTHONY TING, RESPONDENTS.
FACTS
Teng Ching Lay died intestate in 1989. Petitioner Henry Teng, her son from a second marriage, filed a petition for the settlement of her estate and was appointed administrator. In the estate inventory, he included a residential property in Malate, Manila, and other assets, alleging they were merely entrusted by the deceased to her son from a first marriage, Arsenio Ting (predeceased), and thus formed part of her estate. Respondents, who are Arsenio’s heirs, moved for the exclusion of these properties. They argued these assets already belonged to the estate of Arsenio, which had been judicially settled in 1975, wherein the Malate property was adjudicated to them. The Regional Trial Court granted the motion for exclusion, ruling the properties were part of Arsenio’s partitioned estate. The Court of Appeals affirmed this decision.
ISSUE
Whether the probate court committed grave abuse of discretion in ordering the exclusion of the subject properties from the inventory of Teng Ching Lay’s estate.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court clarified the limited jurisdiction of a probate court, which is primarily to settle the estate of the deceased. It does not extend to the final adjudication of ownership disputes over properties claimed by third parties, such as the respondents who derive their title from a different estate (that of Arsenio Ting). While a probate court may make a prima facie determination on whether to include or exclude a property in the inventory for purposes of administration, such determination is merely provisional. The rule requires that the question of ownership be ventilated in a separate action. In this case, the separate action had already been concluded. The Court noted that in a prior case, Hko Ah Pao v. Ting, it had already categorically ruled that the Malate property belonged to Arsenio’s estate. This prior final judgment constitutes res judicata in the concept of conclusiveness of judgment, barring re-litigation of the issue of ownership. Consequently, the probate court correctly excluded the properties, as their ownership had been conclusively settled in favor of respondents, and petitioner’s claim of an implied trust or advanced legitime could no longer be entertained.