G.R. No. L-28947, L-29235, L-30935. January 17, 1973.
Manuel Y. Macias, petitioner-appellant, vs. Ricardo Vito Cruz, et al., respondents-appellees.

FACTS

Julian A. Wolfson died intestate in 1964. His sole heir was his sister, Rosina Marguerite Wolfson. Before his death, Julian left a memorandum requesting Rosina, after settling his estate, to deliver specific sums to named individuals, including petitioner Manuel Y. Macias who was to receive P500. Rosina died in 1965 before fulfilling this request, leaving a will that named the University of Michigan as her residuary legatee. In the intestate proceedings for Julian’s estate (Sp. Proc. No. 57405), Macias filed a motion to be furnished copies of all notices, claiming status as a beneficiary under Julian’s memorandum. The court denied this motion on November 10, 1966, a ruling Macias did not appeal.
Subsequently, the estate administrator, Ricardo Vito Cruz, filed a motion for partial distribution of Julian’s estate to Rosina’s estate. The court granted this via an order dated May 12, 1967. Upon learning of this order, Macias filed a petition for relief on July 20, 1967, arguing the order was void for lack of notice and hearing, and that the fees awarded were exorbitant. The court denied his petition, leading to this appeal consolidated with related petitions concerning Rosina’s testate estate.

ISSUE

The primary issue is whether petitioner-appellant Manuel Y. Macias has legal standing to challenge the orders in the intestate estate of Julian Wolfson, particularly the order for partial distribution.

RULING

The Supreme Court dismissed the appeals and petitions. Macias lacks legal standing to intervene in Julian’s intestate proceedings. His claim stems from a mere memorandum from Julian to Rosina, which created no direct obligation from Julian’s estate to Macias. The memorandum was a personal request to Rosina, not a testamentary disposition. Consequently, Macias is not a creditor, heir, or person with a legal interest in Julian’s estate under the Rules of Court. His proper recourse was to file his claim against the estate of Rosina, the obligor under the memorandum, which he did in her separate testate proceedings.
The Court further ruled that the petition for relief from the May 12, 1967 order was filed out of time. Relief from a final order must be sought within sixty days from knowledge thereof and not more than six months after entry. The order denying his motion for notices was issued on November 10, 1966. Macias filed his petition for relief in July 1967, well beyond the six-month reglementary period, rendering the May 1967 order final and unassailable. His failure to appeal the November 1966 order barred him from later contesting proceedings from which he was properly excluded. The Court found no merit in his attempts to champion other unnamed beneficiaries, emphasizing that the actual heirs and legatees never questioned the administrator’s actions or the court’s distributions.