G.R. No. L-15341; July 20, 1961
IN THE MATTER OF THE TESTATE ESTATE OF JOSE COLLANTES, deceased, FELIX COLLANTES and ANITA RIUS DE COLLANTES, petitioners-appellees, vs. JUAN M. COLLANTES, ET AL., oppositors-appellants.

FACTS

Petitioners Felix Collantes and his wife Anita Rius de Collantes filed a petition on September 19, 1957, for the probate of the last will and testament of the deceased Jose L. Collantes, Felix’s full-blood brother. The decedent, a resident of Manila, died a bachelor on August 8, 1957. The petition alleged he left a one-third pro indiviso share in a real property in Manila valued at approximately P38,780.00, plus unverified bank deposits. The petitioners prayed for the issuance of letters testamentary to Felix, who was named executor in the will. Oppositors Pacita, Maria, Juan, Antonio, and Celerina, all surnamed Collantes, objected to the petition, seeking a declaration of intestacy. Juan Collantes specifically alleged the estate’s value was approximately P176,000.00. The Court of First Instance of Manila, finding the will was executed and attested in accordance with law, issued an order on January 21, 1959, admitting the will to probate and granting letters testamentary.
The oppositors filed motions for reconsideration and a motion for new trial, all of which were denied by the lower court. They initially filed a notice of appeal to the Court of Appeals but subsequently amended their record on appeal to pray for the case to be forwarded to the Supreme Court instead, alleging the estate’s value exceeded P50,000.00. In their brief, the oppositors assigned five errors, primarily challenging the competency and credibility of Anita Rius de Collantes as a witness to the will’s execution, the due execution and attestation of the document, and the sufficiency of the evidence for probate.

ISSUE

Whether the Supreme Court has appellate jurisdiction over the case, or whether it falls within the jurisdiction of the Court of Appeals.

RULING

The Supreme Court ruled it did not have jurisdiction and ordered the case certified to the Court of Appeals. The legal logic is grounded on the statutory distribution of appellate jurisdiction based on the value of the estate and the nature of the questions raised. The Court noted that the amount involved in the proceedings did not exceed P200,000.00. Furthermore, a review of the assigned errors revealed that most raised purely factual questions, such as the credibility of a witness and the factual circumstances surrounding the execution and attestation of the will. Under Section 2 of Republic Act No. 2613 , which governed the appellate jurisdiction at the time, the Court of Appeals had jurisdiction over cases where the amount involved did not exceed P200,000.00 and where the issues were primarily factual. Since the estate’s value was within this threshold and the oppositors’ appeal largely contested factual findings of the probate court, the Supreme Court correctly determined the Court of Appeals was the proper forum. The resolution did not touch upon the merits of the will’s validity but was a procedural determination on the appropriate appellate jurisdiction.