G.R. No. 224550. March 06, 2023
CHAM TENG HUI AND JAMES L. CHAM, PETITIONERS, VS. WILSON P. CHAM AND BERNARD P. CHAM, RESPONDENTS.

FACTS

Allen Cham died intestate on December 4, 1994, without a spouse, ascendants, or legitimate/illegitimate children. Petitioners Cham Teng Hui and James L. Cham filed a Petition for Issuance of Letters of Administration, claiming to be nephews of Allen Cham. Respondents Wilson P. Cham and Bernard P. Cham, among other oppositors, intervened, claiming to be grandchildren of Allen Cham’s brother. The Regional Trial Court (RTC) defined the issue as “[w]ho are the legal heirs of and are entitled to share in the estate of the decedent Allen Cham.” Petitioners filed two Motions for Summary Judgment seeking to exclude oppositors from the intestate proceedings, arguing that oppositors, as 4th-degree collateral relatives, were excluded by petitioners, who were 3rd-degree collateral relatives, and that oppositors had no right of representation. Oppositors opposed, arguing the motions lacked required supporting affidavits and that a genuine issue existed regarding petitioners’ own right to inherit, as Allen Cham was allegedly an illegitimate child of the common ancestor. The RTC initially denied the first motion but granted the second, excluding oppositors. Oppositors filed a Petition for Certiorari before the Court of Appeals (CA). Pending the CA decision, the parties entered into a Compromise Agreement, which the RTC approved via a Judgment. The CA later granted the certiorari petition, annulling the RTC’s summary judgment orders, ruling that genuine issues of fact precluded summary judgment. Petitioners appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in ruling that the Regional Trial Court committed grave abuse of discretion in granting the Motion for Summary Judgment and excluding the oppositors from the intestate proceedings.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the CA’s decision. Summary judgment is only proper when there is no genuine issue as to any material fact. In a petition for appointment of an administrator, the court must determine who among the parties has the best interest in managing the estate, and valid contentions regarding the parties’ respective rights to inherit create a genuine issue for trial. Here, the oppositors consistently contested petitioners’ right to inherit, alleging Allen Cham was an illegitimate child, which raised a genuine factual issue on heirship that required a full trial. The RTC’s summary judgment resolved the issue of heirship prematurely. Furthermore, the subsequent Compromise Agreement and Judgment based thereon did not render the case moot, as the CA correctly proceeded to resolve the certiorari petition to correct the RTC’s grave abuse of discretion in issuing the summary judgment, which was a void judgment for having been rendered without jurisdiction. The Compromise Agreement also expressly waived all of oppositors’ rights and claims to the estate, thereby recognizing petitioners’ hereditary rights, which further supported the CA’s annulment of the summary judgment orders.