GR L 10618; (October, 1917) (Digest)
G.R. No. L-10618, October 26, 1917
Intestate Estate of Miguel Guzman. Rafaela Guzman, petitioner-appellee, vs. Juan Anog and Reinaldo Anog, opponents-appellants.
FACTS:
Rafaela Guzman filed a petition for the summary settlement of the intestate estate of Miguel Guzman under Section 597 of the Code of Civil Procedure, as amended by Act No. 2331 , which applies to estates not exceeding ₱3,000 in value. The petition alleged that two parcels of land formed part of the estate. Juan Anog and Reinaldo Anog, sons of the deceased, opposed the petition, claiming absolute ownership of the lands by adverse title, independent of any right of inheritance from the deceased. They asserted that the deceased never possessed or held title to the properties. Over the appellants’ objections, the trial judge summarily determined title to the lands and ordered their distribution among the heirs.
ISSUE:
Whether a probate court, in summary settlement proceedings, has jurisdiction to adjudicate questions of ownership over properties claimed by third persons under title adverse to the estate.
RULING:
No. The Supreme Court reversed the trial court’s judgment and dismissed the petition. The Court held that a probate court, including one conducting summary settlement proceedings under Chapter 29 of the Code of Civil Procedure, lacks jurisdiction to determine questions of ownership when property is claimed by third persons under title adverse to the deceased and the estate. Such contentious issues must be resolved in an ordinary action before the court in the exercise of its general jurisdiction as a Court of First Instance. The summary nature of the proceedings provides even less justification for adjudicating adverse claims than regular administration proceedings. Since the only property involved was the land claimed by the appellants and the decedent died in 1899, the petition should not have been entertained. The petition was dismissed without costs in the Supreme Court, with costs in the first instance imposed on the petitioner.
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